The credit guidelines to limit light trespass created by the building and site lighting being confined to the property is appropriate for most situations, but is incompatible with the requirements of transitional traffic zones that enter and exit the property and therefore generally located on the property line for most applications. The lighting provided at the property line for road entrance and exit locations serves a variety of purposes, namely: 1. The property area for the road crossing location is an area of potential pedestrian-vehicle conflict. This area requires an appropriate level of illumination for the safety of the pedestrians and for clear visibility of vehicle operators. 2. The area in question is an intersection. Illuminating Engineering Society of North America (IESNA) RP 8 (Standard Practice for Roadway Lighting) recommends that the illumination levels at vehicle conflict locations be increased above similar recommended roadway lighting levels. 3. Vehicle traffic will require a minimal amount of transitional lighting when leaving or entering a lit roadway. Variations in illumination have detrimental effects to the driver that increase the potential for an accident. 4. Provides awareness of vehicle traffic outside of the property to potential inflow of new vehicles. The particular application of this credit interpretation concerns a hospital emergency centre located in a downtown area with high traffic and pedestrian volumes. The site includes a surface parking area for emergency response and public vehicle traffic responding to the emergency centre. Individuals entering the property will often be unfamiliar with the environment and will therefore require a degree of illumination that promotes an awareness of the surroundings allowing them to safely navigate the area. The lighting design for the facility takes into consideration recommended practices outlined in the LEED credit for reducing light pollution. All exterior luminaires are provided as full cut-off type with internal source shielding ensuring no direct illumination is provided above the horizontal plane to limit any spill lighting. With the exception of traffic conflict areas, the exterior lighting design has confined all illumination within the property boundaries. IESNA RP 8 item 3.6.2 states ".driveways serving high volume activities.should be illuminated similar to a major/major intersection." Item 3.6.4 states ".traffic conflict areas should be provided with illuminance values 50 percent higher than recommended for the street." Surrounding roadways would be classified as "collector" routes with "high" degrees of potential pedestrian conflict locations. Table 9 of IESNA RP 8 suggests that the average maintained illumination at the pavement level for this type of intersection be provided with 24.0/2.4 (lux/fc). This is significantly higher than the 6.0/0.6 (lux/fc) level requirement of LEED. The Lake Union District CIR (08/16/2003) addresses spill lighting from the property, but not specifically with respect to traffic intersection. The lighting levels provided at the traffic intersections located for our project design are provided more closely in compliance with IESNA RP 8 for recommended lighting levels at the traffic boundary locations. For our application, the spill lighting will be provided onto a roadway and no lighting will penetrate adjacent property windows. The levels dictated however are inadequate for the recommended lighting requirements of this application. For pedestrian safety, it is imperative to provide an appropriate level of illumination that meets the requirements of all involved. Without a re-evaluation of the lighting requirements of this credit, it will not be possible to provide for the recommended practice lighting levels for most projects at traffic congestion locations. It is requested that the LEED credit requirements allowing no light trespass at the property line be relaxed at traffic conflict locations and be more closely defined so as to allow the designer the ability to provide the appropriate lighting levels for these locations while meeting the intent of the credit.