Light Rays

Paula Alvis Parlier

Light Rays

Around the world there is growing awareness of the life-threatening and life

-altering impacts light pollution has on wildlife and human life.

There are four kinds of light pollution:

- light trespass

- skyglow

- glare (excessive brightness that interferes with vision,

such as headlight glare)

- clutter (bright, confusing, excessive groupings of light

sources such as times Square in NY City).

This Paula’s Pass Along message will focus on light trespass and skyglow.

Introduction:

Our loss of night is not insignificant. The disastrous consequences of artifi-

cial light blindness have led to a global movement to restore the night.

DarkSky International is an organization that advocates to protect the night

sky. With over 70 chapters around the world, and more than 193,000 supporters,

members and advocates in Argentina, Australia, Austria, Brazil, Canada, Cyprus,

Czech Republic, Germany, Greece, Hungary, India, Ireland, Israel, Italy, Japan,

Kenya, Malta, Mexico, Pakistan, South Korea, Switzerland, United Kingdom, United

States, and Uruguay, there is abundant evidence that people care about Nature,

and that they also hope for a bright (or should I say dark-nights) future for all

living beings.

The American Medical Association (AMA) has found that there is over-

whelming evidence that light pollution contributes to or causes the health prob-

lems described in this message. AMA Council on Science and Public Health partici-

pates in scientific research and efforts to reduce light pollution, including blue

light research, and has posted guidelines for cities to follow in order to regulate

lighting, in recognition of increasingly substantial proof that many species, includ-

ing humans are being harmed by the loss of darkness at night, and by light pollu-

tion/artificial lighting.

Blue light is especially destructive to melatonin production. It is a compo-

nent of cell phones and light-emitting diodes (LEDs), and used widely in industrial

and city lighting because it is cheap and energy efficient. One such use is in park-

ing lot lighting. Commercial flood lights in parking lots are generally LED lights,

but any lights that remain on at night contribute to sky glow.

Loss of The Night:

In their powerful exposé, “The Right to the Night: New Legal Advocacy

Strategies to Address Terrestrial Light Pollution”, published in 2024, Dana Zart-

ner, Aparna Venkatesan, and John Barentine provide a comprehensive examina-

tion of the risks to the health and well-being of humans, animals, communities

(both locally and globally), and to Nature itself, caused by the ever-increasing

loss of darkness.

In their opening statement, they emphasize the seriousness of the shifting

status quo that is our night on Earth, “Light pollution has increased so dramati-

cally, that, within a single generation, approximately half of the stars in the night

sky visible to the unaided eye will disappear from view.” The authors go on to

say, “Scientists estimate that … night-sky brightness [is] doubling approximately

every seven years.”

The loss of darkness causes many physical health problems. It “disrupts

natural circadian rhythms, leading to insomnia and other sleep disorders.” The

Right to the Night” p. 35-36; AMA REPORT 4 OF THE COUNCIL ON SCIENCE

AND PUBLIC HEALTH (A-12) “Light Pollution: Adverse Health Effects of

Nighttime Lighting”. It causes “hormonal fluctuations”, which may lead to a varie-

ty of mental and physical health issues. Loss of darkness leads to heightened

“rates of human morbidity and mortality by affecting conditions such as obesity,

diabetes, cardiovascular disease, endocrine disorders” and “cancers” such as

“breast and prostate”. “The Right to the Night”; AMA REPORT 4. It has even

been “linked” as a “potential” “contributing factor” to the “onset of dementia and

Alzheimer’s disease”. “The Right To the Night” p. 35-36; Dr. Yu Xu and the

Shanghai Institute of Endocrine and Metabolic Diseases. The World of Chinese,

theworldofchinese.com, “Lights Off: China Finally Takes Action on Light Pollu-

tion”.

“In addition to resetting the circadian pacemaker, light also stimulates ad-

ditional neuroendocrine and neurobehavioral responses including suppression of

melatonin release from the pineal gland [normal release] improv[es] alertness and

performance. “ AMA REPORT 4. “Even low intensity nighttime light has the capa-

bility of suppressing melatonin release. In various laboratory models of cancer,

melatonin serves as a circulating anticancer signal and suppresses tumor growth.

Limited epidemiological studies support the hypothesis that nighttime lighting

and/or repetitive disruption of circadian rhythms increase cancer risk. …” AMA

REPORT 4.

Some of us experience light blindness more severely than others to begin

with. For me, ultra violent rays are especially harmful. As I grew older, the rap-

idly–increasing loss of night darkness made my circadian rhythm go berserk, and

the number of hours of sleep I was able to get decreased progressively.

My Experience:

As an auburn-haired, fair-skinned young girl, I didn’t notice that I was

looking down at the ground whenever I walked outdoors. It wasn’t until I was in

my fifties and had undergone cataract surgery, that I realized the sun had al-

ways bothered me.

Cataract surgery left my already-sensitive eyes permanently and severely

impaired. I tried desperately to replace the lenses, when I learned that the ma-

terial in them was most likely the worst material makeup, of the available kinds

of lenses, for my eyes. But neither my optometrist, nor the surgeon, nor the doc-

tor I contacted at the University of Davis were willing to offer any remedial as-

sistance. I wanted to immediately remove the lenses and replace them. But, I

was told that that would not be approved. I was further told that within a few

weeks the lenses would settle in and it would be significantly more difficult to

remove them.

I argued that it was my desire as the patient and that the profession rou-

tinely removed and replaced lenses that caused infection or other damage that a

doctor could readily observe. The UC Davis doctor agreed, but said that cataract

surgery was now considered safe and the methodology and machinery to remove

and replace natural lenses was time-tested and virtually fool-proof. Removing and

replacing the new lenses, however, was too risky for doctors to be comfortable

with, he told me. They were not willing to risk the possibility of litigation in the

event something went wrong, including the possibility of blindness.

What could be done? Nothing, I supposed.

More than 10 years later, I still can’t go outside without special sunglasses

and a hat. And, yes, I still look down at the ground.

...the glorious sun

Stays in his course and plays the alchemist,

Turning with splendor his precious eye

The meagre cloddy earth to gliering gold…

UV Rays:

The sun’s light rays are electromagnetic waves - radiation that travels, well,

at the speed of light. As a child, I thought of the sun’s rays in surreal images of

its shiny beams spilling down through the heavens, splitting billowing clouds, and

creating spectacular light shows for us humans below. I still imagine the sun’s

glow like that. Shakespeare’s description, in King John, put it radiantly …

Lens replacement to correct for cataracts, at an early age for that kind of

procedure, brought new reflection on those very same rays, however. For me,

they were now piercing darts of light from our star’s powerful ray gun, blasting

Earth with lethal Ultraviolet Rays. UV rays - UVA, UVB and UVC - that damage

human eyes, causing cataracts, macular degeneration, photokeratitis and pinguic-

ula, and bombaring California residents with a thousand watts per square meter

(W/m

) of the irradiated death rays every day.

W/m

is the IS (solar irradiance) unit for measuring radiant flux

(irradiance) which is the power of radiant energy received per unit area.

The UVE, Erythemal irradiance, is W/m

multiplied by 40m

/W to convert

to the UV index, that sun bathers and farmers use to protect themselves from

exposure. The Global Solar UV Index ranges from Low <2 to Extreme ll+.

I haven’t researched for studies that connect the sun, heat, light, and UV

rays to maladies of the eyes, but my gut tells me that UV light and artificial light

pollution in all its forms, are co-conspirators to the degradation of eyes and

brains, simultaneously.

Melatonin:

Studies have shown that artificial light has been an indirect cause of heart

disease and cancer in humans, due to its ability to significantly lower the produc-

tion of melatonin.

Melatonin is a natural hormone that is released by the body when there is

darkness, and is inhibited when light is present. It is what allows us to fall asleep.

When melatonin levels are lowered, sleep deprivation ensues. Chronic sleep

deprivation is a scary thing. It results in fatigue, headaches, stress, anxiety, and

can even lead to or exacerbate high blood pressure, obesity, heart disease, de-

pression, and other existing health conditions. It can affect cognitive function,

mood, and immune system function. Memory problems and slowed reaction time

can result. Prolonged lack of sleep can lead to hallucinations and even death.

In my case, the drain on melatonin levels is especially harsh because of my

underlying disease. I have Ménières disease.

More disconcerting than being unable to walk outside and enjoy the out-

doors, is the continuing degradation to my health and well-being caused both by

sunlight and, more pointedly for purposes of this message, from artificial light.

Ménières Disease:

It turns out, my life is based on that all-encompassing hierarchical guiding

light known as Murphy’s Law. That is to say, if anything could go wrong for me, it

will go wrong. In fact, for many years I had a phone number, given to me by the

cell phone company Sprint, that belonged previously to a man named Frank Mur-

phy. Creditors would call and ask for Frank, and I’d tell them I wasn’t Frank. They

then accused me of being Mrs. Murphy and refused to believe that I was not his

wife protecting him. After ignoring calls from out of the area for many years, I

finally gave up, got a new phone from a different company, and changed my num-

ber.

The reason I bring up Murphy’s Law here, though, is because I am one of

the unlucky few who has to deal with the symptoms of Ménières disease, which is,

apparently, a rare disease.

Let me describe those symptoms as they have progressed and then explain

how artificial light has unquestionably affected my ability to sleep and how light

pollution is damaging the health and well-being of every living creature, including

humans and other animals on this planet, and including me.

Ménières (mayn - ee - airz) disease is characterized by progressive hearing

loss, tinnitus, fullness of the head that is accompanied by loud roaring and acute

sensitivity to noise, especially loud noise, an illusory sensation of movement in the

head which is caused by damage to the vestibular organ in the inner ear.

In my 20s, I was getting dizzy a few times a year. By “dizzy” I mean that

sensation you get when you stand up too fast. It would last for less than an hour,

then I would have a headache for about an hour. I learned to sleep in a dark quiet

place for an hour or so to regain my normal state.

This continued and progressively worsened over several decades. I sought

the help of doctors and ENTs, but wasn’t diagnosed with Ménières until I was in

my 60s. Prior to that time I was given antihistamine and, because I didn’t know

how random episodes could be, I thought it helped.

My first big attack was when I was 55. It was the end of the school day,

and I knew immediately what was happening when it hit. I told one of my second

grade students to run to the office and get the principal. She came immediately

and helped the students to go home for the day, while I put my head on my desk

and remained still.

Soon I was on the floor and dry heaving. An ambulance came because I was

in so much misery. I didn’t open my eyes for five hours. Tests were run, but there

were no answers given.

After I got home, I slept. For years I had found that I could “bring on” a

bout of dizziness if I failed to get 7- 8 hours of sleep a night. So, I began taking

melatonin as needed to help me sleep. I realized early-on how important sleep was

for me.

Meanwhile, I was losing my hearing in my left ear. I had had tests done

when I went to ENTs and general physicians, trying to find a cause. But, my hear-

ing was mostly fine back then. There was only a slight hiccup in one frequency.

Then, in November 2020, I had the second big attack. At 3:00 in the morn-

ing I woke suddenly to screaming in my ears - like fire engine sirens in my head.

My boys came running. We didn’t know what to do. They helped me downstairs

and I remember throwing up and not having any control over the excruciating

spinning. It was unbearable to open my eyes - the nystagmus was so severe. It

felt like someone was shaking my head violently from side to side. My eyes were

literally shifting back and forth at high speed. That is the nystagmus, caused by

the inner ear, which is out of whack, and the brain trying to correct the imbal-

ance of the world I perceive, but getting such confused messages that it was jar-

ring my brain around, making me nauseous and out of control.

After that, I went to my primary physician and told her I wanted to see a

doctor who specializes in Ménières disease. I had checked for the necessary

symptoms to make such a diagnosis, and, because I had just had second bad at-

tack, I knew for sure that I had Ménières. My doctor sent me to four doctors, an

ENT (ear nose and throat), a neurologist, a sleep doctor and, if I remember cor-

rectly, an audiologist, because, as it turns out, there are no specialists for Mé-

nières. Murphy’s Law.

Finally, in 2021, I was sent to an ENT at University California San Francisco

(UCSF) hospital. Doctor Sharon worked with me for a year. There isn’t much that

can be done, but, I did have six prednisone shots in my left ear. Things calmed

down for a while, with on-going periods when my head and ears were full and loud,

making me anxious and paranoid and unable to enjoy music or make out clearly

what was being said on the phone. When tinnitus would suddenly scream, for a mi-

nute or so, my hearing would decrease along with my emotional stability.

Then, in the summer of 2024, vertigo, the worst symptom of Ménières, hit

with a vengeance. Violent episodes would come unexpectedly and last 1-3 hours.

Each experience was excruciating, and most were accompanied by vomiting and

terrible spasms and nausea. The episodes have lasted for a year, with intermit-

tent lulls for a few days or weeks at a time, and have not subsided altogether.

I learned to recognize some triggers - when I would have menopausal-like

night sweats, for example, I knew it was coming. I tried to stay cool, keeping the

AC low and sitting in front of a fan. I tried to stay indoors. I tried to shield my

eyes from light and cover all the sky lights and high decorative windows. There

wasn’t much I could do. My head would be on fire. I used wet cloths and held my

head, moaning and vomiting until each episode passed.

Light was causing my eyes to sting, and I wasn’t getting nearly enough sleep,

which perpetuated the dizzy spells. The lack of sleep left me light-headed and on

the verge of a full-blown attack round the clock.

I tried sleeping with a mask over my eyes, and sometimes it worked, but

eventually nothing worked. I was no longer producing enough melatonin. The body

needs darkness to produce it. Taking melatonin pills stopped working. Even large

doses didn’t help.

At my house, there was too much light from street lights and neighboring

homes. Shades blocked some light, but I was trying to catch up on lost sleep, and

daytime light was causing a new problem that shades didn’t prevent.

I had to start wearing a mask, but it was pretty difficult, because anything

on my head would cause it to overheat and bring on a full-blown episode.

Fall and winter didn't ease my discomfort, but by spring of 2025, I was

having longer periods of relief. Happiness returned slowly. I began to get full

night’s sleep much more often.

Reedley/Fresno County:

So, I started going to visit my 96-year-old father in Reedley, California, in

the house where I was born and raised and where my mother was raised. The

house was built by the Parlier family, my grandparents. It had been in Reedley,

out in the country for more than a century. After I had moved away and after my

mother died, which was in November 2017, the facility behind our property,

which had been Ito’s Packing and was now Sun Pacific and Moonlight, built an

enormous fenced-in parking lot directly adjacent to our property, property which

is now held in trust for my brothers and me.

The parking lot, which is separately fenced and gated, is not used at night.

Though diesel trucks sometimes enter. Nevertheless, the whole area, which ap-

pears to be a few acres in size, is lit up like a football field, with towering light

poles and bright flood lights that remain lit throughout the night.

When I stay at my family home, I sleep upstairs. The window does not face

the parking lot. Still, the light is so intense that is like mid-day at night.

Needless to say, I often get little to no sleep when I am there. My father

sleeps in the only downstairs bedroom and only bedroom that is opposite to the

parking lot. His sleep is un-interrupted. He also has little exposure to blue light,

as he does not own a computer and spends negligible time on his cell phone. But

for everyone else who stays in the house, the light is a major disruptor.

I would like to spend extended time with my father and I am considering

moving there for a time to be with him while I still can. But, that simply is not

possible now that my disease has progressed, because I need sleep that I cannot

get there because of the parking lot lights.

The Affect of Impaired Sleep on Ménières Patients:

Ten acclaimed doctors, both from Japan and UC Davis, the United States,

conducted in-depth studies, in 2010, regarding the affects of impaired sleep on

Ménières’ patients. In an article called, “Impaired Quality of Sleep in Ménières’s

Patients”, the doctors summarized their findings as follows:

“...Ménières’s disease patients who were refractory [didn’t respond] to

medical management might suffer from poor quality of sleep or high arousal with

little deep sleep, possibly combined with OSAS [Obstructive Sleep Apnea Syn-

drome] or PLMD [Periodic Limb Movement Disorder]. Poor quality of sleep may

cause additional stress and lead Ménières’s disease patients to a negative spiral

of symptoms.” [Emphasis added.]

Definitions of ALAN, Sky Glow and Light Trespass:

Artificial light at night is called ALAN.

Skyglow is the artificial brightening of the night sky from human light

sources, that have become so intense that darkness is increasingly obscured.

“Europe and the East Coast of the United States shine particularly bright but

dominate clusters of ALAN are visible across every continent except Antarctica.”

The Right to the Night” p. 34.

Light trespass is usually caused by those same light sources, but is usually

thought of as a local (neighbor-to-neighbor) intrusion.

Light Trespass:

Dana Zartner, co-author of “The Right to the Night”, grew up in Dayton,

Minnesota, catching fireflies and counting stars. But, as companies like Federal

Express, Budweiser, Graco and Bobcat built manufacturing and distribution cen-

ters on Minnesota land once used for farming, the night became less dark, pre-

venting this kind of human activity. Massive warehouses with copious towering

floodlights shone through the night, filling the heavens with sky glow that could

be seen for miles.

It is the same problem we face in Reedley from the Sun Pacific parking lot

lights.

Sun Pacific doesn’t need light to protect a parking lot. In fact, it could be

argued that the parking lot causes crime rather than preventing it. Vandalism

during hours when people are exiting the parking lot, began on our property not

long after the lot was built. People “party” and screech their tires in the lot and

throw their trash over the chain link fence onto our side.

Our home was built by my mother’s family, the Parlier family, over a century

ago. It was once a beautiful forest-like haven, surrounded by evergreens, and it

was far enough in the country to be somewhat isolated. To the northeast, the

snow-covered Sierra Nevadas were picture perfect in the winter, blue and ma-

jestic in the spring. But when Sun Pacific took over, two gigantic cold storage

buildings were built that stretched across the entire length of the back of our

plot, blocking out the mountain range entirely.

Later, the parking lot and the lights were added. Overnight, the property

that was my home and my mother’s home, a lovely sanctuary for a hundred

years, turned into a prison-like enclosure with football stadium floodlights

guarding an empty parking lot all night, every night. There is also the uninten-

tional creation of sanctuary for wild and domestic animals on our property. The

property is not lit up at night, and it is not fenced off. It has become a safe

place for a family of skunks in the basement, which is accessible through a dirt

entrance. Hundreds of birds are protected on the property because there are

so many trees and insects. Cats and dogs from neighbors stary onto the prop-

erty and sometimes make it home, all to my father’s consternation. A stray cat

recently killed a dove that had made a nest under a first-story eave and had

been sitting on eggs for many days. Animals find a way to survive when they

can, but the Sun Pacific compound is an impenetrable environment for wildlife,

so they are attracted to our property, which has places they can hide from the

light.

Light Trespass is Not Legal/Common-Law Nuisance:

International and domestic laws exist that can be used or have been used

to protect individuals and communities against light trespass, especially when

there is direct harm, as there is for me. The trespass can be a nuisance when

light spills over from a neighboring property or public area, causing glare or

causing other disturbance such as sleep disturbance.

This is an actionable cause used most frequently in the United States.

California law provides that a nuisance, which is a type of conduct that

disturbs the use or enjoyment of one’s property is actionable in a court of law.

Oceanside, California’s municipal code defines light trespass as “...light emitted

by … outdoor lighting … that directly illuminates beyond the property on which

… [the light source] is installed.”

Some ordinances restrict hours during which outdoor lighting can be used,

often requiring lights to be extinguished after a certain time at night. Mono

County, San Luis Obispo, Riverside, and LA County have specific ordinances to

protect the night sky and that require turning lights out at night in most cases.

Local Laws:

I believe that, if an action was brought on the basis of light trespass, Fres-

no County Courts would find that the lights in Sun Pacific’s parking lot do cause

harm against individuals and that they do constitute a preventable nuisance.

I feel certain that both state and federal courts in Fresno County will ex-

amine the precedential holdings and substantial scientific and medical evidence

to conclude that light trespass causes significant harm and that it must be cur-

tailed, and that the parking lot lights maintained by Sun Pacific should be re-

moved or modified to come on only if motion requires and then only a single and

low-lit light should trigger.

Reedley Municipal Code Chapter 4 of Reedley, CA Code of Ordinances Ordi-

nance No. 2024-009 Section 1 9-4-4 E specifically prohibits light trespass and

light pollution, and outdoor lighting must be maintained in such a manner as to

prevent light trespass.

Global Impact:

Light pollution impacts more than the physical health of humans. Noctalgia,

or sky grief, is a kind of depression based on the loss of our surrounding environ-

ment - our natural home - the security of the night sky that surrounds us and

twinkles down on us.

The loss of darkness severely harms other life as well, “… animals, plants

and entire ecosystems that rely on the natural cycles of light and darkness to

survive and thrive.” “The Right to the Night” p.32. Animal behavior is changing.

Migration patterns are being disrupted. Circadian Rhythms are impacted. Habit

formation is being altered or blocked. Sea turtles and birds guided by the moon’s

light lose their ability to navigate when sky glow confuses them. This confusion

results in death for millions of nocturnal animals wanderers. Huge numbers of in-

sects are disappearing due to artificial lighting that they are drawn to. The loss

of insects greatly reduces the primary food source for birds and many other

small creatures. “The Right to the Night.” “A common estimate states that a

small back-lit advertising box kills about 350,000 insects per year.” the-

worldofchinese.com, “Lights Off…”.

The National Audubon Society says that 80% of all migrating bird species

use the night sky to migrate. The Almanac, “State bill aims to dim artificial light

from California’s night skies” Olivia Wynkoop January 2, 2023, almanacnews.com.

In the Bay Area, millions of birds using the Pacific Flyway are distracted

off track by sky glow. The Almanac “State bill aims to …”. “...researchers from

Duke Kunshan University in Jiangsu province found that artificial light causing a

loss of direction as one of the main reasons that birds crashed into buildings, the

second biggest contributing factor to bird deaths worldwide.” [Emphasis added.]

“Lights Off…” Not only does artificial light affect birds’ ability to navigate, but

light pollution has also been shown to negatively impact the mating practices of

birds. “The Right to the Night” p. 37.

Many cities are proactive in an attempt to protect migrating birds, adopting

“Lights Out” programs to turn off building lights during migration. “The Right to

the Night”; “black-out” program” in Lanshan county, China, “Lights Off…” (The

irony here is that “Lights Out” turns off building lights to protect birds but

doesn’t protect people from light trespass or sky glow, which is a nightly intru-

sion in every season.)

“Exposure to ALAN affects animals’ ability to find mates and reproduce;

reduces their options for finding food; and interferes with communication.” “The

Right to the Night” p. 38.

Plants are affected. Growth cycles are interfered with. “Plants’ photorecep-

tors have evolved to sense the daily and annual variations of light quality and

quantity. If this is disrupted it can lead to an inability to track seasonal changes

in the length of the day that signal when to shed and grow leaves.” “The Right to

the Night” p. 38. I think any of us who have lived around plants, or crops have

noticed the shifting seasonal changes.

Even life in the ocean is affected. Filter-feeding animals avoid areas that

are lit, such as those on oil rigs, passing ships and harbors. The more light that

penetrates the shallows and the depths of oceans, the fewer marine ecosystems

there will be to inhabit ocean expanses. “The Right to the Night.”

In response to the mounting problem, the National Park Service (NPS) mon-

itors night sky brightness, and is actively engaged in prioritizing nighttime dark-

ness.

International DarkSky Association (IDA) works to preserve the natural

night sky. It certifies parks and other places as dark sky reserves. There are

over “60 dark sky parks, communities and reserves in the United States”. The re-

serve in “Idaho is 1,400 square miles”.

After you have finished reading this article, start paying attention to how

much light there is in your city at night. It is astounding. Lights from businesses,

huge plants, industrial plants that are purely aesthetic and protect no homes,

gates and home subdivision entrance ways, lights surrounding schools that shine

inside and outside, porch lights, and billboards.

Sun Pacific’s lights are by no means an anomaly. They contribute to the sky

glow that fills the night sky, masking darkness all over the globe; all to the detri-

ment of each of us. And the monetary cost to keep the lights on is astronomical.

Cultural Genocide and Celestial Navigation:

The loss of night and our ability to see the heavens with our own eyes has

led to a form of “cultural genocide” for many. And this too has resulted in sky

grief.

Many communities, including indigenous cultures, practice beliefs, rituals

and ceremonies that honor and draw from a relationship with Nature, including a

deep connection to the dark skies and the rhythm of days and nights. Many other

communities connect the environment with spiritual beliefs and practices.

Such communities and cultures are protected, sometimes through domestic

systems and certainly under international laws which have interpreted existing

protections to include the right to night darkness as a cultural and spiritual right.

Additionally, for millions of years, our ancestors have used the stars “… to

mark the changing of the seasons and the passage of time, for navigation, to de-

termine the time for harvest, and …” to marvel at and to observe the cosmos, and

to begin and continue the process of astronomy. “The Right to the Night”

Light pollution and the loss of darkness is an infringement on everyone’s

freedom of enjoyment, whether it be through their culture, health and happi-

ness, spirituality or a desire to observe and learn or wonder.

“The star-filled dark sky has an incredibly important place in human cul-

tures and ‘[h]as shaped the beliefs and traditions of societies, from the Native

American origin and cultural landscape stories, to the celestially-aligned archi-

tecture of ancestral Puebloan civilizations, to agricultural harvest festivals and

nautical navigation records to sea voyages.” “The Right to the Night”.

The loss of darkness due to increasing light pollution is therefore a viola-

tion of one of the most fundamental rights in both international and domestic

law. “...The freedom of religion in international law recognizes not only the mono-

theistic religions, but also spiritualities and cultural practices that encompass na-

ture - including the stars and the night sky - in their practices.” “The Right to

the Night” p. 63.

Public Trust:

The public trust doctrine is the most reasonable method of justice to pro-

tect the earth and all that is on and in it from abuse and damage and to protect

the future rights of people and all life to exist and thrive.

The doctrine holds “that certain natural and cultural resources are pre-

served for public use”. “The Right to the Night” p. 51.

The doctrine represents universal rights that have been upheld in many

countries. It has been effective in environmental law cases, including climate

change cases and where environmental harm has occurred. The underlying thrust

is that a government or governments have failed to uphold a duty to protect the

public from harm, including environmental harm. “According to Joseph Sax, a

leading legal scholar on the public trust doctrine, it is a legal tool that any citizen

could use to fight exploitation of resources that should rightfully be protected

common property. “The Right to the Night” p. 52.

Now I will bombard you, the reader, with many, many examples of case law,

success stories, ordinances and the like, that support this idea that government

has a responsibility to protect the environment for the public good, for those liv-

ing and those yet unborn, and that this includes protection of dark nights.

1. Many state constitutions provide for the right to a healthful environment

and hold the state and individuals responsible for maintaining and improving the

environment for present and future generations. Montana is a shining example.

2. California legislators are beginning to recognize the problem. AB 38

would reduce light pollution coming from state-owned property in California.

3. 19 states, including Arizona, Texas, and New York, have “dark skies” leg-

islation in place, for purposes that include human health.

4. Mike Lynes, policy director for Audubon California, “… is hopeful that

California can inspire change in how private homeowners, businesses and munici-

palities use their lights, especially as the state continues to expand.” Almanac-

news.com, “State bill aims to dim…”.

5. Caltrans and Calif Dept of Fish & Wildlife are researching ways to reduce

light emissions.

6. The California Green Amendment, ACA 16 would amend the California

State Constitution and would add a right to clean air, water, and a healthy envi-

ronment, and would establish a constitutional duty for government officials to

protect these rights equitably. The amendment was stymied, but is likely to pass

in the future as more citizens understand that their natural rights should be

codified.

7. More than six U.S. states expressively protect the public right to a

healthy environment. “The Right to the Night” p. 58.

8. Mark Baker, founded Soft Lights Foundation, in Oregon, which is run

wholly by volunteers. The group files lawsuits against cities and businesses for

LED light discrimination, and light trespass nuisance and against the federal gov-

ernment for failing to regulate LED Visible Light radiation from LED headlights,

LED streetlights, LED light bulbs, and LED flashing lights on emergency vehicles.

9. January 2024 Baker filed a federal lawsuit against Food & Drug Admin-

istration for failing to protect public from harms of LED lights and failing to

comply with 21 U.S.C. 360hh - 360ss to publish standards for LED products to

ensure health, safety and civil rights of the public.

 Note: USFDA is the only federal agency with authority and mandate to

regulate electromagnetic radiation from electric products in the United States.

10. December 2024 Baker filed suit against several government agencies

planning to install thousands of LED lights on San-Francisco-Oakland Bay Bridge.

The suit alleges that the project, Bay Lights 360, will cause significant environ-

mental discrimination against individuals who cannot tolerate LED lights.

The proposed light display would be visible for miles. The suit addresses

damage to marine life and bird life whose habits will surely be further and sub-

stantially disrupted by the increased light in the bay.

The suit also argues that California Environmental Quality Act requires

state and local agencies to protect the environment and “adopt all feasible

measures to mitigate the impact of proposed projects.”

11. Governor Newsome and state Senator Wiener are not aware of the sig-

nificant issues caused globally by sky glow. Newsome has vetoed legislation that

would protect the night, and Wiener believes the lights on the bridge are merely

“an art installation” that have no impact on the environment.

12. The troposphere is the only part of our atmosphere in which humans can

survive. It is the sky space around our living areas. We have the right to treat

our sky as commons property that should be enjoyed by Earth’s inhabitants. Just

as a resident has the right to be free from someone shinning search lights in a

bedroom window, people have the right to be free from sky glow that disrupts

their right to look up at the night and see what is beyond us. Every nation should

join in declaring a universal, global right to the night.

13. “...the public trust doctrine views public goods as those natural and cul-

tural recourses and spaces that belong to no one, but are important for everyone;

and these public goods include the night sky…” “The Right to the Night” p. 52;

Terrel Gallaway, The Value of the Night Sy, in URBAN LIGHTING, LIGHT POL-

LUTION AND SOCIETY (1st el. 2014); Fabio Falchi et al., A Call For Scientists

to Halt the Spoiling of The Night Sky with Artificial Light and Satellites, 7 NA-

TURE ASTRONOMY 237 (2023), https://doi.org/10.1028/s41550-022-01864-z.

14. The atmosphere is viewed as a public trust natural resource. “The Right

to the Night” p. 53; Juliana v. United States, 339 F. Supp. 3d 106 (9th Cir. 2020).

15. “Given the extensive use of the public trust doctrine, and its corre-

sponding protection of the environment for future generations, applying these

same arguments to address the negative impacts from increasing light pollution is

a logical extension.” “The Right to the Night” p. 55 (115)

16. “When it gets to the point we see now of increased sky-glow that is in-

fringing on the darkness, it is clear governments are failing in their responsibili-

ties to protect the public populations and, therefore, must be held responsible.”

“The Right to the Night” p. 55.

China:

Country after country is waking up to the realization that dark nights are

necessary.

In 2020, the Shanghai Astronomical Observatory (SHAO) found that

Shanghai's night sky brightness had increased 100 times over a 20-year period.

The World of Chinese, theworldofchinese.com, “Lights Off: China Finally Takes

Action on Light Pollution”. The 1.5-meter optical telescope, “once the biggest in

East Asia” had to be moved to a dimmer area in 2015 because light pollution had

made it unusable. “Lights Off…”

Light pollution has become one of China’s biggest environmental problems.

China categorizes light pollution into three causes: reflection or white light pollu-

tion reflecting light off buildings in the daytime, skyglow caused by electrical il-

lumination during nighttime; and color light pollution from colored lights. “Lights

Off”

Light pollution effects well over half of China’s people. Nearly half cannot

see the Milky Way. Shockingly, in Europe and North America, the percentage is

much higher. At least 80% (and by some accounts 99%) are unable to see our own

galaxy.

In 2019, lighting made up 20% of overall electricity consumption in China.

Some ophthalmologists there believe that the major reason so many high school

students (possibly more than half) have been diagnosed with myopia (near-

sightedness) is because their visual world is polluted and that that has caused

damage to their eyes. “Lights Off…”.

Spectacular light shows in China attract millions of people, and China relies

on light ceremonies, light shows, and LED billboards to attract tourists and in-

vestors, including Chengdu’s Tianfu New Areas’ twin IFC towers, that are used to

display brightly lit video that illuminates the full expanse of the towers.

But, the cost is unsustainable, both the financial cost and the cost to the

environment and to human health. As was the case for the East Bay bridge light-

ing in San Francisco, millions were spent to light up Baiyulan Plaza in the Puxi dis-

trict. It cost Chinese investors 90 million yuan to illuminate the tallest building

there. Duplicating the effort for just “20 additional buildings” (and there are

“far more along the Huangpu River”) would mean spending a “billion yuan” just for

display value. “Lights Off…”.

Such an extravagance was unthinkable for the Chinese government, not

even taking into consideration the electrical waste. The Chinese government has

reacted more swiftly and efficiently, so far, to light pollution than the federal

government in the United States..

China is responding to the threat of light pollution. “In 2019, the central

government announced that it would rectify excessive ‘landscape brightening pro-

jects,’ ‘vanity projects,’ and ‘image projects,’ condemning local governments for

wasting money and social resources. In 2021, delegate Li Dajiin at the National

Congress, China’s highest legislature, proposed to introduce nationwide laws on

light pollution. This August, [2023] Shanghai became the first city in China to

legislate against light pollution and punish violators, who could be fined up to

50,000 yuan for a first offense.” “Light Off…”.

It is indeed difficult to give up the beauty that decorative lights provide. I

love Disneyland’s electrical parade. I bought a gamers’ keyboard that’s lit to

slowly change colors. I’ve bought solar lights to display my trees at night in my

front yard, and I enjoy changing them out to match the seasons and monthly

themes. I even wait for the consumer warning on movie videos that change color.

Colored lights and white light displays are dazzling, but, like a decadent choco-

late fudge sundae, these are temptations we can no longer indulge. It took a long

time for me to become educated in this regard. But I finally understand how I am

harming myself and the night, not as much as Sun Pacific perhaps, not nearly as

much as Tang Paradise theme park in Xi’an,

but if I can change - corporations and governments can too - they must, now that

we know how harmful light pollution has become.

Other Countries and the United Nations Understand the Importance Of

Regaining the Night:

Spain’s Canary Islands declared their intent to protect the night in La Palma

Declarative, which was created by a group that included Starlight Initiative, The

La Palma Biosphere Reserve, the government of the Canary Islands, and the

Spanish Ministry of the Environment. The declaration recognizes the right to un-

polluted night as a human right [fundamental right] and that degradation of dark-

ness must be rectified. “The Right to the Night” p. 46

France, Italy, Croatia, the Czech Republic and Spain have taken measures to

limit light pollution and to protect night skies. “The Right to the Night” p. 47

The small island country in the South Pacific mid-ocean, Niue, was the first

country to recognize the need to protect darkness and is the first Dark Sky Na-

tion. The Mᾱori are leading the charge to make New Zealand the second certi-

fied Dark Sky Nation.

The United Nations Committee on the Peaceful Uses of Outer Space

(COPUOS) created a “Dark and Quiet Skies” initiative. “The Right to the Night”

p. 46.

Rights of Nature Movement:

There is a growing movement that gives standing to Nature. It began with

Sierra Club v Morton, 1975 and Justice Douglas’ “A Wilderness Bill of Rights” to

The night skies, or natural darkness, possesses inherent rights to ex-

ist and flourish, as well as inherent rights to restoration, recovery,

and preservation. These rights include, but are not limited to, the

right to be free from light pollution, both terrestrial and orbital; the

right to be free from overcrowding due to satellites, as well as the

right to be free from human activity that may adversely impact the

Night.

protect people whose spiritual customs honor and include Nature. The case was

the first of this kind. It gave birth to the field of environmental law. Massive

protests to save the Mineral King area, which is now a part of Sequoia National

Park, grew out of the case and paved the way for Nature to deserve standing.

The wheels of justice turn slowly, but today there is a shift in cultural and

environment awareness. Globally, judicial holdings recognize Nature as an entity

with standing: the Amazon, the ocean waves, Lake Erie, Te Urewera rainforest,

the Wanganui River, Bangladeshi rivers, the Ganges River, the Atrato River, and

hopefully soon, the night sky (and all the oceans).

“The Right to the Night” p. 67

Human connection to the environment is crucial for our survival. Under-

standing that concept requires a universal mind-shift. It means “…

rethinking...world views, shifting from the idea that Nature is merely a commodi-

ty to one where it is recognized as an independent…” entity which must be pro-

tected. By protecting natural resources - Nature in general - we, in turn, protect

ourselves. Indeed, one of the major reasons that internationally, courts are pro-

tecting Nature, is due to concerns over human health due to environmental deg-

radation. “The Right to the Night” p. 68; Waorani of Pastaza vs. Ecuadorian

State. In that case, “the Inter-American Court of Human Rights ordered the Ec-

uadorian government to protect Indigenous groups from oil operations and to

leave the oil in the ground…”. Case law has also granted personhood to Nature

and to the Amazona. Demanda Generaciones Futuras v. Minambiente, Corte Su-

prema de Justicia (April 5, 2018), STC4360-2018. In that case “...the Colombian

Court held that the right to a healthy environment is a fundamental right and

protecting the rights of the Amazon is a key component of ensuring the right to

a healthy environment, as well as other rights, are protected.” “Right to the

Night” footnote 90 p. 51.

Energy Costs and Global Warming Reduced by Turning Lights Off:

Lighted parking lots and lighting that is too bright or unnecessary is a huge

waste of energy, in addition to the enormous environment consequences I’ve men-

tioned.

According to DarkSky International, U.S. outdoor lighting consumes 380

terawatt – hours (tWh) of energy per year, enough to fuel “49 million” passenger

cars for a year. DarkSky International, darksky.org, “Light is Energy: Estimating

the Impact of Light Pollution on Climate Change”.

DarkSky tells us that, in a single year, the U.S. wastes about 120 tWh of

energy for outdoor lighting, the bulk of which is used to light city streets and

parking lots. “That’s enough energy to meet New York City’s electricity needs for

two years!” DarkSky International, darksky.org, “ Light pollution wastes energy

and money and damages the climate”.

DarkSky states that “30%” of outdoor lighting is wasted, and that “$3.3

billion to $4.5 billion” (with a B) is spent on unnecessary and unmanaged lighting.

If the outdoor lighting was turned off, DarkSky says that “21 million tons” of

carbon dioxide emission would be prevented, per year.

According to DarkSky, scientists estimate that global light emissions pro-

duce “150,000 gigawatt-hours” of energy each year. “Globally we spend at least

$50 Billion in energy costs each year to produce light that escapes into space.”

DarkSky “Light is Energy: Estimating the Impact of Light Pollution on Climate

Change” DarkSky International, darksky.org.

“Electricity powering outdoor light at night also represents about 6% of

world carbon dioxide emissions, contributing to global climate change.” “The

Right to the Night” p.38.That is a lot, and it’s preventable.

The U.S. Department of Energy has determined that “99%” of artificial

light is not used for “human eyes to interpret their surrounding”. It is wasted.

DarkSky International, darksky.org, “Light is Energy…”

Over the past few decades, lighting has become cheaper. Apparently this

has led to a “rebound effect”, which means, instead of reducing lighting, people

use more of it, all to the detriment of the planet, and us.

By the way, DarkSky’s estimates of cost and harm are admittedly low.

Their estimates are out of date, in that they were calculated prior to the 2021

surge in energy costs and the enormous drain on energy due to the Russian inva-

sion of Ukraine. I imagine that the Israeli-Palestinian conflict has also drastical-

ly increased the lighting usage and cost.

The underestimated usage and cost makes the actual figures even more

alarming, and provides another major reason to reduce greenhouse gas emissions,

and one that is much easier to accomplish than many others.

Briefly, with regard to the amount of light necessary for outdoor lighting,

poorly shielded and overly bright lights are especially wasteful and dangerous.

Such lighting decreases the ability to see objects by reducing contrast, and cre-

ating shadowing, thereby wasting money and energy in the process. The affect on

eyes can be especially harmful as they deteriorate with age. DarkSky Interna-

tional, darksky.org, “Light pollution affects human health”.

Final Thoughts:

My purpose in writing this message is not a political one. Well actually it is

in a way. My son Cameron says everything is political. And I do want to help peo-

ple decide what to believe. I am not advocating a power structure, that is, the

right to the night issue shouldn’t be about which politician to believe or which

party to trust. Rather, understanding how to protect humans, wildlife and the

earth has to be about a new mindset, a more enlightened view of Nature and

health and preservation of the human right to appreciate the dark - observation

of constellations, the beauty of the dark skies, stargazing, and so on, and also to

protect the rights of present and future generations physically, emotionally,

mentally and existentially, and, finally, to protect Nature itself in order to pro-

tect everything else.

There is a huge and growing movement peopled by scientists, astronomers,

medical professionals, anthropologists, environmentalists, gardeners, animal lov-

ers, park rangers, marginalized groups, indigenous people and government offi-

cials to bring back the night.

Scientific input is crucial to our understanding of what is happening and

what we can do to reverse the problem. But the most important factor to bring

about change is public awareness and, ultimately, a complete shift in current

thinking - a new mindset.

We need societal shifts. We need to be comfortable with darkness at night.

We need to believe that the night does not need to be lit up. We need to con-

vince businesses and cities to extinguish night light and to save billions of dollars

on the wasted energy they use. The belief that lights protect people is largely

unsubstantiated. The warehouse my brothers maintain has motion detector

lights, but they don’t seem to deter the people who have stolen equipment and

trailers and painted graffiti on the outside walls. The school where I was em-

ployed was consistently vandalized despite its lit surroundings.

This is an issue that I believe we can all wrap ourselves around. I think we

need to believe we can make a difference. Advocating for dark nights is one way

we can. Here are things I’m doing: I have turned the lights off of my keyboard

and turn the screen off on the monitor whenever it is not in use, including right

now as I type these words, in addition to turning the computer off when I’m

asleep. I don’t leave a porch light on at night. (My father has a motion detector

on the Parlier home for night protection). I am sending this message to Reedley

City officials and to Sun Pacific to ask them to turn off the parking lot lights,

and save money. I plan to talk to the local ACLU to help me if needed.

We have a misguided belief that more, bigger, and brighter is better. We

have to change that misconception. Growth is unsustainable. Too much of any-

thing ultimately causes a crash - too much CO

, too much political power, too

much light.

We can protect darkness. As communities, we can begin to value Nature

again, and to recognize the ways in which light pollution is changing our sleep cy-

cles and our peace of mind.

I predict that, if tests were conducted, most people in America and Europe

would show melatonin levels far below what is needed for sufficient sleep, espe-

cially in older people as natural production diminishes. I have the suspicion that

people in cities with bright skies have drastically low levels. I think that, if stud-

ies were conducted, we would find that most of us are tired and feel like we are

not getting enough sleep. We need the dark.

The night sky connects us, through our desire to understand - science; our

culture - art, origin stories, rituals that bind us to Nature, stargazing and so on;

and through our human need to nurture and protect- human health and wildlife,

as well as the troposphere itself.

We are losing our dark nights and it feels a lot like going blind. We have a

fundamental right to enjoy the night and to be well-rested and to feel secure.

I urge you to think about this more and to learn more. I hope I have moti-

vated you.

Here’s wishing you a good night’s sleep.

Always,

Paula

Bibliography

AMERICAN MEDICAL ASSOCIATION REPORT 4 OF THE COUNCIL ON SCI-

ENCE AND PUBLIC HEALTH (A-12). “Light Pollution: Adverse Health Effects of

Nighttime Lighting.” Action of the AMA House of Delegates 2021 Annual Meet-

ing: Council on Science and Public Health Report 4 Recommendations Adopted as

Amended, and Remainder of Report filed.

Baker, Mark. “FDA SUED: SOFT LIGHTS FOUNDATION ACTS AGAINST LED

HEALTH RISKS.” Environs Environmental Health Trust, Jan. 23, 2024, https://

ehtrust.org/federal-lawsuit-filed-against-fda-led-health-risks/

DarkSky Staff. “Light pollution affects human health.” DarkSky International,

September 3, 2014 Updated April 14, 2025, https://darksky.org/resources/what

-is-light-pollution/effects/human-health/

DarkSky Staff. “Light pollution wastes energy and money and damages the cli-

mate.” DarkSky International, September 8, 2014 Updated Oct. 17, 2023,

https://darksky.org/resources/what-is-light-pollution/effects/energy-climate/

He, Anita. “Lights Off: China Finally Takes Action on Light Pollution.” The

World of Chinese, January 6, 2023, https://

www.theworldofchinese.com/2023/01/lights-off-china-finally-takes-action-on-

light-pollution/#:~:text=In%202021%2C%20delegate%20Li%20Dajin%20at%

20the,to%2050%2C000%20yuan%20for%20a%20first%20offense.

Ellis, Maliya. “Calif. man sues over BayLights installation, alleging light pollution

an discrimination.” San Fransisca Chronicle Hearst newspapers 2025 Hearst

Communications, Inc., Dec. 18, 2024, https://

www.theworldofchinese.com/2023/01/lights-off-china-finally-takes-action-on-

light-pollution/#:~:text=In%202021%2C%20delegate%20Li%20Dajin%20at%

20the,to%2050%2C000%20yuan%20for%20a%20first%20offense.

Nakayama, Meiho M.D., Ph.D., and Motohiko Suzuki, M.D., Ph.D., Akira Inagaki,

M.D., Ph.D., Keiji Takemura, M.D., Ph.D., Nobuhiro Watanabe, M.D., Ph.D., Tohru

Tanigawa, M.D., Ph.D. Kazushi Okamoto, M.D., Ph.D., Hirokazu Hattori, M.D., Ph.D.,

Hilary Brodie, M.D., Shingo Murakami, M.DD., PhD.. “Impaired Quality of Sleep in

Ménières Disease Patients.” JCSM Journal of Clinical Sleep Medicine, Vol. 6 No.

5, 2010, https://jcsm.aasm.org/doi/pdf/10.5664/jcsm.27933#:~:text=Current%

20Knowledge/Study%20Rationale:%20The%20relationship%20between%20M%

C3%A9ni%C3%A8re%27s,sleep%2C%20possibly%20combined%20with%

20OSAS%20or%20PLMD.

National Geographic Education. “Light Pollution.” National Geographic Society,

April 10, 2025, https://education.nationalgeographic.org/resource/light-

pollution/

Reedley, CA Code of Ordinances, Ordinance No. 2024-009, “AN ORDINANCE

OF THE CITY COUNCIL OF THE CITY OF REEDLEY AMENDING CHAPTER 4

OF TITLE 9 OF THE REEDLEY MUNICIPAL CODE CONCERNING BUILDING

REGULATIONS OF LIGHTING FIXTURES, Section 1. Section 9-4-4 (E)

Scorzafava, Lauren. “Light is Energy: Estimating the Impact of Light Pollution

on Climate Change.” DarkSky International, August 2, 2022, https://darksky.org/

news/light-is-energy-estimating-the-impact-of-light-pollution-on-climate-

change/

Suresh, Monishaa. “Riverine Rights Around the World—Three Case Studies.”

GW The Point Source George Washinton University Law School GW Environmen-

tal and Energy Law, blogs..gwu, April 19, 2023, https://blogs.gwu.edu/law-

gwpointsource/2023/04/19/riverine-rights-around-the-world-three-case-

studies/

Surma, Katie. “Landmark Ruling on Uncontacted Indigenous Peoples’ Rights

Strikes at Oil Industry.” Inside Climate News, March 13, 2025, https://

insideclimatenews.org/news/13032025/landmark-ruling-uncontacted-indigenous-

peoples-rights-ecuador-oil-industry/

Wynkoop, Olivia. “State bill aims to dim artificial light from California’s night

skies.” The Almanac, January 2, 2023, https://www.almanacnews.com/

news/2023/01/02/state-bill-aims-to-dim-artificial-light-from-californias-night-

skies/

Zartner, Dana, and Aparna Venkatesan, John Barentine. “The Right to the

Night: New Legal Advocacy Strategies to Address Terrestrial Light Pollution.”

Environs Environmental Law and Policy Journal, December 2024, https://

environs.law.ucdavis.edu/archives/48/1/right-night-new-legal-advocacy-

strategies-address-terrestrial-light-pollution