Public Comment Requesting a Comprehensive Light-Pollution Mitigation Plan for Micron’s Proposed Complex in Clay, NY
August 11, 2025
RE: Lighting best practices should be required at Micron’s proposed complex in Clay, NY, to protect biodiversity and lighten loads on the regional energy grid
To Whom It May Concern,
I am writing on behalf of Lights Out Central New York to express concern about Micron Technology Inc.’s draft lighting plan for its proposed complex at White Pine Commerce Park in Clay. Micron’s lighting plan needs to be significantly revised so that light pollution is minimized at the site during construction and operations. Given the complex’s proposed location in a pristine, sensitive wetland area, the U.S. Department of Commerce and the Onondaga County Industrial Development Agency should require Micron to follow best lighting practices throughout the site.
All luminaires, lights, and lighting practices at the site should follow the highest industry standards. These are articulated in LEED v5’s Interior Lighting and Light Pollution Reduction credits. We recommend that Micron be required to follow these standards throughout the proposed complex, whether or not Micron seeks LEED certification for any part of the site.
Studies show that light pollution is growing at an alarming pace, with satellite and ground-based measurements revealing that North Americans experience more than 10% annual increases in artificial light (Kyba et al., 2023). Artificial light at night poses serious threats to local fauna and flora, ecosystems, and also public health. Clay is located in the Atlantic Flyway, a migration route for over 300 bird species. Artificial nighttime lighting causes significant disorientation for migratory birds and associated mortality due to building collisions, while affected bird populations are in steep decline (Rosenberg et al, 2019).
Lighting doesn’t just affect wildlife—excessive nighttime lighting has also been linked to human health risks. A 2016 study from the American Medical Association warns that artificial light exposure at night is associated with increased risks of sleep disorders, obesity, depression, and even certain cancers (Motta, 2024).
Following industry best practices, lighting should only be installed and used if absolutely necessary—no decorative or façade lighting should be allowed, particularly after 11pm. For lights deemed necessary, they must be controlled with modern technologies: automatic timers, motion sensors, and dimmers should be used that automatically turn off or dim at least 70%. All outdoor luminaires should be full-cutoff; lights should be at the lowest possible lumen level (intensity), and in warm tones (2,500K or less).
Because lighting needs can be substantial at large tech facilities, following industry best practices would also help reduce energy demands at the complex and ease pressure on the regional grid—and ease burdens on the local energy market affecting residential customers.
By adopting best lighting standards for both its construction and operations, Micron would avoid preventable ecological damage, help protect biodiversity, and demonstrate that it is serious about being a good neighbor that follows sustainable development best practices.
Therefore, Lights Out CNY urges the U.S. Department of Commerce and Onondaga County Industrial Development Agency to request Micron Technology, Inc. to revise the lighting plans for its proposed complex to include a comprehensive light-pollution mitigation plan, so that, if the project is approved, Micron’s legacy in the area is one of environmental stewardship and conscientious lighting, not one of easily preventable harms to local biodiversity, public health, and the night sky.
Sincerely,
Meredith
Meredith Barges, MA, MDiv
Chair, Lights Out Central New York
Board Member, Onondaga Audubon Society
