Transport Scotland - LED trunk road lighting information: EIR release

Information requested

Thank you for your response of 10 April 2026 and for providing sample documentation relating to LED trunk road lighting, including design records, environmental management plans, and asset information.

Having reviewed the sample materials, I am writing to refine and narrow the scope of my request under the Environmental Information (Scotland) Regulations 2004, in order to focus on specific categories of information which appear to be held but were not included within the sample disclosure.

To assist in making my request proportionate and targeted, I would be content for the information below to be provided for a defined sample area or scheme, such as the Thurso area referenced in Annex C, or another representative trunk road scheme of your choosing.

1. LED Lantern Technical Specifications

• Make and model of LED lanterns used
• Technical specifications including:
  correlated colour temperature (CCT)
  spectral power distribution (if held)
  photobiological safety classification (e.g. IEC/EN 62471)
  lumen output and wattage

2. Lighting Design Standards and Guidance

• Copies of any standards, guidance documents, or technical specifications used by Operating Companies
• Any internal or contractual requirements supplementing recognised standards such as BS EN 13201 Road Lighting Standard or guidance from the Institution of Lighting Professionals

3. Scheme-Level Environmental Consideration of Lighting

Any recorded information considering the environmental impact of lighting once operational, including:

• light pollution or sky glow
• ecological or wildlife impacts
• mitigation measures

4. Contractor / Operating Company Design Documentation

• ​​​​​​​Lighting design manuals, specifications, or requirements used by Operating Companies such as Amey or BEAR Scotland

5. Post-Installation Monitoring or Review

Any recorded information relating to:

• monitoring or evaluation of LED lighting schemes
• internal reviews
• complaints or recorded impacts (e.g. glare, brightness, environmental concerns)

6. Information Held on Behalf of Transport Scotland

Where information is held by Operating Companies on behalf of Transport Scotland, I request that this is considered within scope in accordance with regulation 2(2) of the EIRs.

7. Assessment of Sufficiency of Standards

In previous correspondence and documentation, it appears that reliance is placed on compliance with recognised standards to support the use of LED lighting.
To clarify the evidential basis for this position, please provide any recorded information which identifies:

• whether any organisation, body, or internal function has assessed that compliance with lighting standards (including but not limited to BS EN 13201 Road Lighting Standard) is sufficient to ensure:
  protection of human health
  protection of the environment (including light pollution and ecological effects)
• if such an assessment has been undertaken:
  who carried it out
  when it was carried out
  what evidence or analysis it was based on
• if no such assessment has been undertaken:
  please confirm that no recorded information is held demonstrating that compliance with these standards has been evaluated as sufficient for these purposes

For clarity, this part of the request relates specifically to recorded information evidencing how the sufficiency of standards has been determined, rather than general descriptions of the standards themselves. 

I would be content for information to be provided in sample form where appropriate.

Response

Q1. Regarding LED Lantern Technical Specifications, you requested the following:

• Make and model of LED lanterns used
• Technical specifications including:
  correlated colour temperature (CCT)
  spectral power distribution (if held)
  photobiological safety classification (e.g. IEC/EN 62471)
  lumen output and wattage

A1. We can confirm that the means to access all of the information you have requested above has already been provided to you in our previous correspondence dated 25 February 2026 Ref 202600505398.

As the information is already available to you, Transport Scotland is applying Regulation 6(1)(b) of the Environmental Information (Scotland) Regulations 2004. This regulation provides that a Scottish public authority is not required to make environmental information available where the applicant already holds that information.

Q2. Regarding Lighting Design Standards and Guidance, you requested the following:

• Copies of any standards, guidance documents, or technical specifications used by Operating Companies
• Any internal or contractual requirements supplementing recognised standards such as BS EN 13201 Road Lighting Standard or guidance from the Institution of Lighting Professionals

A2. We can confirm that all of the information you have requested above has already been provided to you in our previous correspondence dated 25 February 2026 Ref 202600505398.

As the information is already available to you, Transport Scotland is applying Regulation 6(1)(b) of the Environmental Information (Scotland) Regulations 2004. This regulation provides that a Scottish public authority is not required to make environmental information available where the applicant already holds that information.

Q3. Scheme-Level Environmental Consideration of Lighting, you requested the following:

Any recorded information considering the environmental impact of lighting once operational, including:

• light pollution or sky glow
• ecological or wildlife impacts
• mitigation measures

A3. Regarding the environmental impact of lighting once operational, we refer to our previous response, Ref 202600505398, where we advised that post installation environmental monitoring of operational lighting schemes is not a requirement of the lighting standards. Therefore, no post installation monitoring of lighting schemes is undertaken unless there is a specific reason for it to be done.

Under the terms of the exception at regulation 10(4)(a) of the EIRs (information not held), Transport Scotland is not required to provide information which it does not have. Transport Scotland does not have the information you have requested because no additional recorded information exists.

This exception is subject to the 'public interest test'. Therefore, taking account of all the circumstances of this case, we have considered if the public interest in disclosing the information outweighs the public interest in applying the exception. We have found that, on balance, the public interest lies in favour of upholding the exception. While we recognise that there may be some public interest in information about ecological or wildlife impacts, clearly we cannot provide information which we do not hold.

Q4. Regarding Contractor / Operating Company Design Documentation, you requested the following:

• Lighting design manuals, specifications, or requirements used by Operating Companies such as Amey or BEAR Scotland

A4. We can confirm that the information you have requested above has already been provided to you in our previous correspondence dated 25 February 2026 Ref 202600505398.

As the information is already available to you, Transport Scotland is applying Regulation 6(1)(b) of the Environmental Information (Scotland) Regulations 2004. This regulation provides that a Scottish public authority is not required to make environmental information available where the applicant already holds that information.

Q5. Regarding Post-Installation Monitoring or Review, you requested the following:

Any recorded information relating to:

• monitoring or evaluation of LED lighting schemes
• internal reviews
• complaints or recorded impacts (e.g. glare, brightness, environmental concerns)

A5. We can confirm that all of the information you have requested above as it relates to the sample schemes previously supplied, has already been provided to you in our previous correspondence dated 25 February 2026 Ref 202600505398.

We have advised that post installation environmental monitoring of operational lighting schemes is not a requirement of the lighting standards. Therefore no post installation monitoring of lighting schemes is undertaken unless there is a specific reason for it to be done.

Under the terms of the exception at regulation 10(4)(a) of the EIRs (information not held), Transport Scotland is not required to provide information which it does not have. Transport Scotland does not have the information you have requested because no additional recorded information exists.

This exception is subject to the 'public interest test'. Therefore, taking account of all the circumstances of this case, we have considered if the public interest in disclosing the information outweighs the public interest in applying the exception. We have found that, on balance, the public interest lies in favour of upholding the exception. While we recognise that there may be some public interest in information about monitoring and reviews, clearly we cannot provide information which we do not hold.

Q6. Regarding Information Held on Behalf of Transport Scotland, you stated the following:

Where information is held by Operating Companies on behalf of Transport Scotland, I request that this is considered within scope in accordance with regulation 2(2) of the EIRs.

A6. In relation to your request that information held by Operating Companies on behalf of Transport Scotland be considered within scope under Regulation 2(2) of the Environmental Information (Scotland) Regulations 2004, we can confirm that Transport Scotland has interpreted your request in line with the requirements of the Regulations.

Regulation 2(2) extends the definition of a Scottish public authority to include certain bodies carrying out public environmental functions under the control of a public authority. However, this does not automatically require all information held by contractors or Operating Companies to be treated as held by Transport Scotland.

Transport Scotland have considered whether any relevant information is held on its behalf, taking into account the nature of the relationship, the level of control exercised, and whether the information is held for Transport Scotland’s purposes. Where information is held on behalf of Transport Scotland, it has been considered within scope of your request.

Q7. Regarding Assessment of Sufficiency of Standards

In previous correspondence and documentation, it appears that reliance is placed on compliance with recognised standards to support the use of LED lighting.

To clarify the evidential basis for this position, please provide any recorded information which identifies:

• whether any organisation, body, or internal function has assessed that compliance with lighting standards (including but not limited to BS EN 13201 Road Lighting Standard) is sufficient to ensure:
  protection of human health
  protection of the environment (including light pollution and ecological effects)
• if such an assessment has been undertaken:
  who carried it out
  when it was carried out
  what evidence or analysis it was based on
• if no such assessment has been undertaken:
  please confirm that no recorded information is held demonstrating that compliance with these standards has been evaluated as sufficient for these purposes

A7. Transport Scotland can confirm that no recorded information is held demonstrating that compliance with these standards has been evaluated as sufficient for the purposes mentioned in this question.

Transport Scotland’s role is to ensure the application and adherence to these standards in the design and implementation of Trunk Road and Motorway lighting. The British Standards Institution, lighting industry bodies, and other European organisations which set these standards have done so with due cognisance of these issues.

It is not the role of Transport Scotland to assess or challenge these standards as they are nationally recognised documents. Any concerns about their validity or scrutiny should be addressed to the relevant organisation directly. Contact information for these organisations was previously supplied in the response to enquiry Ref: 202600505398.

While our aim is to provide information whenever possible, in this instance Transport Scotland does not have the information you have requested. Therefore we are refusing your request under the exception at regulation 10(4)(a) of the EIRs.

Under the terms of the exception at regulation 10(4)(a) of the EIRs (information not held), Transport Scotland is not required to provide information which it does not have. Transport Scotland does not have the information you have requested because no assessments have been completed however we can confirm that this demonstrates that compliance with these standards has been evaluated as sufficient for these purposes.

This exception is subject to the 'public interest test'. Therefore, taking account of all the circumstances of this case, we have considered if the public interest in disclosing the information outweighs the public interest in applying the exception. We have found that, on balance, the public interest lies in favour of upholding the exception. While we recognise that there may be some public interest in information about Assessment of Sufficiency of Standards, clearly we cannot provide information which we do not hold.

I would like once again to extend my offer of a meeting to discuss any of your questions further, to allow us to fully understand your needs around this subject matter, and to help us conclude with responses to your satisfaction. I will continue to assist, however it is important to understand what Transport Scotland and its operational partners roles are in relation to the setting, application, and assessment of the suitability of the lighting standards, and therefore the limitations on us in providing what you ask for.

About FOI

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