Transport Scotland LED trunk road lighting Information: EIR release
Information request and response under the Environmental Information (Scotland) Regulations 2004
Information requested
You stated " Thank you for your email of 30 January 2026 and for taking the time to provide further detail on the types of information held in relation to trunk road LED lighting. I appreciate your engagement and your efforts to assist.
I would like to clarify at the outset that my request remains a formal request under the Environmental Information (Scotland) Regulations 2004, and my intention is to understand what recorded environmental and related information is held by Transport Scotland (including via its Operating Companies) concerning the design, assessment, implementation, and management of LED trunk road lighting.
I am grateful for your explanation of the categories of information that may exist, and I can confirm the following.
1. Samples of information
Yes, I would be content to receive sample examples of:
- LED lighting design records
- Environmental management or environmental consideration documents prepared on a per-scheme basis
- Asset and maintenance records relating to LED lighting
Receipt of samples would be helpful to understand the nature, scope, and structure of the information held. This should not be taken as narrowing or replacing my original request, but rather as an initial step to assist clarity and proportionality.
2. Environmental considerations
I note your confirmation that environmental management plans and environmental considerations are undertaken at scheme level. This is helpful and directly relevant to my request, particularly where such documents consider impacts such as light pollution, night-time environment, ecological effects, or human exposure. I would welcome an example of such documentation.
3. Geographic scope
While I understand the scale of the trunk road network and the volume of assets involved, I would prefer to review sample information before specifying particular locations. This will allow any subsequent refinement to be informed and proportionate, rather than arbitrary.
4. Health and environmental remit
I note your position that public health and environmental risks are addressed through compliance with industry standards. For clarity, my request is not limited to compliance documentation alone, but includes any recorded information showing how environmental effects were identified, considered, or managed as part of lighting schemes, including where this was delegated to or delivered by Operating Companies.
I appreciate your offer to discuss this further and may take you up on that once I have reviewed the sample information. For the moment, I would be grateful if the requested sample documents could be issued under the EIRs.
Response
1. (a) Samples of information
You stated, Yes, I would be content to receive sample examples of:
- LED lighting design
Please see documents named Annex A 1-12 ,extracts from our Operating Company’s lighting design software, which shows the positions of lighting columns and types of luminaries required to satisfy the lighting requirements across the respective schemes. Also included is the design check certificates for both schemes.
An exception under regulation 11(2) of the EIRs some of the information requested because it is personal data of a third party and disclosing it would contravene the data protection principles in Article 5(1) of the General Data Protection Regulation and in section 34(1) of the Data Protection Act 2018.
This exception is not subject to the 'public interest test', so we are not required to consider if the public interest in disclosing the information outweighs the public interest in applying the exception.
1. (b) Environmental management or environmental consideration documents prepared on a perscheme basis
Please see Annexes B1 and B2 attached to this response for copies of the Environmental Management Plans for both chosen sample schemes. I would highlight that these are largely environmental management plans to support the implementation of the construction scheme, as opposed to containing detail around the effects of the LED lighting post installation. As previously stated this aspect is managed by adherence with the standards set out by the wider lighting industry and scientific community.
An exception under regulation 11(2) of the EIRs applies to [some of the information requested because it is personal data of a third party and disclosing it would contravene the data protection principles in Article 5(1) of the General Data Protection Regulation and in section 34(1) of the Data Protection Act 2018. This exception is not subject to the 'public interest test', so we are not required to consider if the public interest in disclosing the information outweighs the public interest in applying the exception.
1. (c) Asset and maintenance records relating to LED lighting
Please see Annex C which contains a spreadsheet extract from our asset management system detailing the lighting inventory within Thurso. Please also see Annex D1 and D2 for screen extracts from our asset management systems which show the maintenance activities undertaken on two sample lighting points.
2. Environmental considerations
You stated " I note your confirmation that environmental management plans and environmental considerations are undertaken at scheme level. This is helpful and directly relevant to my request, particularly where such documents consider impacts such as light pollution, night-time environment, ecological effects, or human exposure. I would welcome an example of such documentation"
As per previous responses, these aspects have been dealt with by the wider lighting industry through research studies and creation of robust LED equipment standards, our Operating Companies are only responsible for deploying this equipment in line with these standards. Annex B contains Environmental Management Plan information our Operating Companies hold.
3. Geographic scope
While I understand the scale of the trunk road network and the volume of assets involved, I would prefer to review sample information before specifying particular locations. This will allow any subsequent refinement to be informed and proportionate, rather than arbitrary.
We note your above statement, and will assist where we can with further proportionate responses once you have reviewed the sample information provided.
4. Health and environmental remit
I note your position that public health and environmental risks are addressed through compliance with industry standards. For clarity, my request is not limited to compliance documentation alone, but includes any recorded information showing how environmental effects were identified, considered, or managed as part of lighting schemes, including where this was delegated to or delivered by Operating Companies.
A sample of the Environmental Management Plan information held is included in Annex B1 and B2.
Lighting designs are undertaken in accordance with industry standards, by trained and competent lighting designers, whose role it is to consider all aspects of a specific scheme in the application of these standards, ultimately resulting in the design outputs contained in Annex A. Any specific information related to environmental impacts highlighted through the design exercise is recorded within the scheme Environmental Management Plans.
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Contact
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Central Correspondence Unit
Email: contactus@gov.scot
Phone: 0300 244 4000
The Scottish Government
St Andrew's House
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EH1 3DG