Public Comment: There’s Still Room To Improve Safety In New Lighting Proposal

The following public comment was submitted in writing for the Town Council meeting of August 7, 2023.

Today, I am writing you once again with concerns about the proposed streetlights policy which is scheduled to be discussed and voted on at the August 7 Town Council meeting under agenda item 8b.  A lot of work has gone into the policy and revising it in response to feedback since the council sponsors first presented it to the council in August 2022. I appreciate those changes, and the policy now is safer and better than what was first proposed. However, in my view, the current proposal still has a number of significant issues from a process perspective and a traffic safety perspective – some of which are due to new language added by the sponsors since the last version (June 2023), and all of which should be addressed before the policy is voted on. I encourage the Council to postpone its vote accordingly. It is not urgent for the Council to vote on the policy at this time. It will likely be years before many of the town’s current streetlights reach the end of their useful lifetime and are replaced, and the current streetlights do not have dimming capabilities. There is therefore time to revise the proposed streetlight policy as now written and:

• Improve its proposed process for streetlight additions and removals to be more equitable and better allow for public input;
• Improve and clarify its proposed process for deciding the extent of streetlight dimming and where streetlights will be dimmed; and
• Better balance the goals of reducing nighttime pollution and the detrimental impacts of excessive light on wildlife and human health, with other Town of Amherst goals such as creating a multimodal transportation network that “contributes directly to the safety, health, economic vitality, and quality of life of all residents including the most vulnerable” (Amherst Complete Streets Policy, adopted 2019), becoming a more age-friendly community (Amherst Age & Dementia-Friendly Community Project, 2022-2023), and reducing greenhouse gas emissions in Amherst, including by promoting a transportation mode shift to more walking and bicycling and less driving (Amherst Climate Action Adaption and Resilience Plan, 2021)

Over the past year, I have shared with you numerous statistics, studies, and best practice guides regarding the increased nighttime traffic safety risks for drivers as well as pedestrians and other vulnerable road users, and how good streetlighting can both reduce those risks and also improve people’s feeling of safety and comfort with walking, biking, and/or taking the bus at night (taking the bus usually involves walking to and from bus stops). I won’t repeat all those data and resources links here, though I am happy to provide them upon request.

In her 3-part series for the Amherst Indy, “Dark Skies and Safe Roads: Can We Have Both?”, UMass geography professor and former TAC member Eve Vogel has gone beyond just sharing links and data, and written extensively and compellingly about the need to have a streetlights policy that includes standards not only related to reducing light pollution (which the policy now contains) but also standards for good transportation safety at night especially for vulnerable road users (which the policy is lacking in). Her pieces include diagrams of what streets would look like in Amherst if the proposed streetlights policy is adopted as is, and detailed recommendations on what changes are needed, based on her extensive research on this topic. I encourage any of you who haven’t done so to read Eve’s articles.

I generally agree with Eve Vogel’s recommendations. Also, below I have listed a few specific, key areas of concern I have with the current proposed streetlights policy:

• The section on page 2 that discusses how “Upon request of the Town Manager, the Town Council may waive any portion of this Policy…. in order to install, remove, or modify streetlighting where such installation, removal or modification would not comply with this policy” and outlines what such a request should include. I had previously recommended that language be added to this section so that whenever a streetlight (or a group of streetlights) is proposed for removal or installation, the Town Council hold a public hearing to facilitate public input on the proposal. I still stand by this recommendation.  In their letter to the council dated 8/1/2023, the sponsors write that “introducing public hearings would bring about a significant gap with regards to equity, when you consider the navigation of the hearing process.” My take on this is different: a public hearing provides an important opportunity for members of the public, especially those who could be most impacted by the removal or installation of specific streetlight(s) to share their concerns or support for such changes, before they are voted on by the Council. As the Keeper of the Public Way under the Town Charter, the Town Council holds public hearings on other requested changes to the public way, for example with proposed new parking restrictions on a street or in a neighborhood, and for the placement of utility poles. Such hearings are not cumbersome – and they are often quite short, such as when no or few members only a few members of the public have any comments – and they increase transparency and equity, by giving anyone interested an opportunity to participate and share their point of view. Just as some residents feel strongly about the on-street parking situation in their neighborhood, some feel equally, if not more strongly, about streetlights in their neighborhood.

• The section in the Appendix (Section B(4)b) which deals with the dimming of streetlight and streetscape lighting. Since the June 2023 version of the policy, the Sponsors have added new language stating that “the specific amount of dimming will be determined by the Superintendent of Public Works after consulting and receiving input from the Town Council” and that “The Town Council may choose to modify this policy to specify the degree of dimming in specific parts of Town.” As it is currently written, I find the second part of this most concerning because of its potential to undermine the Sponsors’ stated intentions of building equitable processes for Town decisions regarding streetlights and of “not privileging those who know navigate complicated systems” and town politics. With the current language, it is possible that councilors could be overly influenced by the loudest voices asking for changes in the degree of streetlight dimming. The council is the Keeper of the Public Way but councilors are generally not experts on streetlighting, nighttime safety, and where it may be most appropriate to increase or decrease dimming. For this section, instead of the recently added language, I would recommend that the policy indicate that the before implementing dimming for town streetlights that the Town Council will develop guidelines, with input from stakeholders, stakeholder committees, staff, and others with expertise, regarding the extent to which streetlights and streetscape lighting will be dimmed at night overall in Amherst, and criteria for deciding which areas of town could appropriate for different levels of dimming. This section of the streetlights could then also say that streetlights will be dimmed in accordance with these guidelines and criteria once they are established.

One other comment on this section: As I have written about and provided data for previously, I continue to strongly believe that in some parts of Amherst, especially corridors with late night (after midnight) PVTA/UMass bus routes and high levels of pedestrian activity, 11 pm is too early to dim streetlights. Cambridge, Massachusetts dims some streetlights at 8 pm, and others at 10 pm, but the streetlights along major roadways in Cambridge are not dimmed until midnight. In Amherst, even midnight could be too early to dim streetlights on major roadways. I encourage the Council to err on the side of caution and safety, and either exclude arterial roadways from dimming or make the dimming start as late as possible and be as minimal as possible at least initially. Research has shown that dimmed streetlights have an adverse impact both on drivers’ ability to see pedestrians walking along a roadway and on how long it takes drivers to slow and yield after seeing a pedestrian (One study: https://doi.org/10.1016/j.aap.2018.08.023).

• The Streetlight Performance Standards in the Appendix, Section B.
  As Eve Vogel has written some of the proposed standards in section do not meet streetlight standards and best practices for nighttime traffic safety, and if implemented would decrease safety for pedestrians and others. Some examples of this are below.  I recommend that the policy’s standards be revised before the policy is adopted to reduce these risks.
  • Section B(2) significantly limits “Light Trespass” (defined as light from a lamp/luminaire that shines beyond the public right-of-way)
  • Section B(3) on streetlights’ color spectrum says that “lamps and bulbs shall not exceed 2700K” (Kelvin, color temperature).

With regards to B(2), traffic safety studies have shown the importance of having some illuminance extending beyond the edge of the roadway in improving drivers’ detection of pedestrians and other objects both in and next to the roadway. Researchers discuss “surround ratio”, a ratio of the illuminance spilling over the edge of a roadway (generally at least one car width beyond the roadway) to the illumination within the roadway and recommend a surround ratio of at least 80% (Source: 2023 FHWA Lighting Handbook; https://highways.dot.gov/sites/fhwa.dot.gov/files/2023-05/FHWA-Lighting-Handbook_0.pdf).  With regards to B(3), the 2023 FHWA Lighting Handbook also discusses research showing that at higher speeds, 4000K LED lighting improves drivers’ ability to detect pedestrians and other roadway objects, more than 3000K or 5000K lighting. The research also shows that 4000K lighting improve detection performance in both high surround ratio and low surround ratio conditions. The USDOT/FHWA’s Pedestrian Lighting Primer (2022) states the following “When selecting the spectral content of a light source, a range of 3000K to 4000K obtains a balance between the potential negative impacts on health and the potential benefits to road user visibility” (https://highways.dot.gov/sites/fhwa.dot.gov/files/2022-09/Pedestrian_Lighting_Primer_Final.pdf). The IPWEA’s Model Public Lighting Strategy, which also aims to balance environmental and safety concerns, recommends 3000K lighting for more residential roads, and 4000 streetlighting for main roads for the best driver and pedestrian safety (https://www.ipwea.org/new-page/communities1/community-home/librarydocuments/viewdocument?DocumentKey=3787e789-41a1-4e44-801c-bc08168c4832).

Tracy Zafian

Tracy Zafian is a resident of District 3 and a member of the Transportation Advisory Committee (TAC). Her views here are her own and and are not made on behalf of TAC or another other committee or organization of which she is a member.