Letter: Proposed Street Light Policy Inadvertently Threatens Pedestrian And Bicycle Safety

The following letter was sent to the Amherst Town Council on June 26, 2023

I am writing to you with comments about the proposed streetlights policy on your agenda for tonight’s meeting.

Summary
I urge you to reject the policy as currently developed. It has important and valuable provisions that reflect careful thinking and diligence of its proponents. However, as currently written, it inadvertently threatens pedestrian and bicycle safety, and will make it much more difficult for the town to build out a safe and inviting pedestrian and bicycle network.

Two crucial things are needed in this policy before it is passed by the council:

1) The performance standards for protection of the night sky and against light trespass need to be matched by equally strong performance standards for pedestrian and bicycle safety. (The streetlights policy defines light trespass in terms of light beyond the right of way. In these comments I use the term in its broader definition of excess light that falls on surfaces or areas that are not intended to be illuminated). These standards also must include recognition of users of mobility devices like wheelchairs and walkers, and of the growing number of micro-mobility devices like scooters, including e-scooters.

2) The policy needs to shed some of its absolute “shall” language, and to outline processes, including public engagement, that will guide future town representatives and decision-makers on how to balance potential tradeoffs among safety, minimization of unnecessary light, and cost.

My Expertise / Background
I served for over 10 years on Amherst transportation committees, including the Public Transportation and Bicycle Committee, the Transportation Plan Task Force, the Transportation Advisory Committee, and the Complete Streets / Traffic Calming Subcommittee. In this capacity, my emphasis has long been on growing a more robust bicycle, pedestrian, and transit network. I have done considerable research into other towns’ and states’ policies, and into our own town’s geography and the challenges of particular locations and routes. While no longer officially on the TAC, I still attend most meetings, and provided input when the proponents of this policy presented to the TAC. Currently I also help lead a multi-union group on the UMass campus on sustainable and just transportation, and I write an occasional column in the Indy called “Mode Shift: Supporting Sustainable and Equitable Transportation.” Professionally, I am a geographer on the faculty of UMass Amherst, working at the intersections of environmental and energy policy. Finally, I am a walker, bicyclist, and transit rider, as well as a driver. For many years I traveled Amherst with my son on a bicycle tag-along.

Pedestrians and bicyclists are three to seven times more vulnerable to fatal accidents in the dark than during daylight hours. Children are particularly vulnerable, and minority communities experience disproprotionate burdens.

Background: Why This Is Important
Pedestrians and bicyclists are three to seven times more vulnerable to fatal accidents in the dark than during daylight hours. Children are particularly vulnerable, and minority communities experience disproprotionate burdens. The information in this background comes primarily from FHWA Office of Safety 2022: Pedestrian Lighting Primer. In addition, I used FHWA: 2023 Lighting Handbooand MassDOT 2015: Separated Bike Lane Planning & Design Guide.)

Lighting is also crucial for users of wheelchairs and other mobility devices. More lighting not only improves safety; it also increases comfort and confidence, increasing use of walking and bicycling paths. Lighting is important not only during the dark but also during low-visibility weather; when it is dark and rainy, pedestrians and bicyclists have even higher visibility challenges.

There are particular things to keep in mind in thinking about how much lighting is needed in order to protect pedestrians and bicyclists. Pedestrians and bicyclists need both to see and to be seen. This may be especially important for certain users or locations—for example, women, children, or areas where there is more illicit activity. People’s vision and visibility depends not only on direct lighting, but also the contrast with other lights and objects. For example, a driver may not see a pedestrian walking on a shoulder who is darker than a headlight-illuminated road. A streetlight on one side of a road may not illuminate a tree-covered sidewalk on the other side. A bicyclist blinded by oncoming headlights may not be able to see road debris or a pothole in front of them—especially if the shoulder they are biking on is inconsistently lit. If a road surface has bright elements, that can aid in making on-road bicyclists or pedestrians more visible—or, depending on the angle from which it is illuminated, it can make them appear dark and less visible. Intersections are particularly dangerous for pedestrians and bicyclists. Line of sight is important, especially for vehicle drivers and bicyclists; the later move considerably faster than pedestrians. When traffic speeds are over 25 mph, a pedestrian or bicyclist who is hit by a car has over a 50% chance of dying. This is a short set of examples that may help councilors understand why specific performance standards are needed that take into account the differential lighting needs of different users in different locations.

In Amherst, assessing and addressing the lighting needs for pedestrian and bicycle safety is unusually challenging for several reasons. One reason is that we have many main roads that do not have sidewalks, do not have bike lanes, or lack both. They also have high traffic speeds—posted speeds are often 30 mph or 40 mph, while many cars go 50 mph or more. Nonetheless, these arterials are often used by pedestrians and bicyclists, and many of these roads are suggested as primary connectors for the Amherst Bicycle and Pedestrian Network. (See Amherst Bicycle and Pedestrian Network Plan p. 28. The final network map has been held up for four years without completion. See: Vogel 2022: Supportong Sustainable, Equitable Transportation. It’s Time To Finish Amherst’s Bicycle And Pedestrian Network Map And Plan Amherst Indy). Update from that Indy article: The Final Plan is now on the TAC website, but the network map stll is unfinished. Nor has the Plan been adopted by the Council.  

Another reason things are complicated in Amherst is that we get thousands of new town residents every September, many of whom have little experience driving, walking, biking, and scooting on dark small town roads. Many nighttime walkers in Amherst do not wear reflective gear or use lights, and drivers new to Amherst often do not think to look for them. A third complication is that we have many miles of roads and streets relative to our population and town budget, many of them narrow, and not enough funds or right-of-way to provide ideal pedestrian, bicycle, and lighting facilities.

Councilors might consider three fatalities in the last decade that happened at night in Amherst:

·   On North East Street, near the Strong St. intersection. Two people were walking on the shoulder side by side. North East Street in that location has few lights and no sidewalk, and the paint striping of the shoulder on which people sometimes walk or bike is often faded. A car driver did not see the two pedestrians, and the person walking on the inside was killed.( Merzbach 2014: University of Massachusetts student killed in Amherst crash Thursday night. Daily Hampshire Gazette).

On North Pleasant St, near the North Village Apartments. A graduate student got off a bus, and crossed the street to go home. Though near an intersection with a streetlight, the bus stop was just enough away, and the car driver did not see him.   (Merzbach 2019: UMass grad student dies after being hit by vehicle in Amherst. Daily Hampshire Gazette.)

·          On Massachusetts Ave, a student was killed near a construction site. There was quite a bit of lighting on and near Mass Ave, but the construction lights and sidewalk blockages likely confused both pedestrian and driver. A number of recent injuries there suggests visibility has remained a problem. ( MilNeil 2022: Crashes Kill One, Seriously Injure Another Student On UMass Amherst’s Main Campus Roadway. StreetsBlogMass.)

In each of these, lack of visibility led to these people’s deaths.

Comments on the Proposed Streetlights Policy:

1. The intent and provisions to protect the night sky and limit light pollution or trespass are valuable. The proponents of the Streetlight Policy have done their homework well, developing a research-supported objective and plan to reduce unnecessary lighting. Unnecessary lighting interferes with night sky visibility, can affect human Circadian rhythms and health, negatively impacts the safety and habitat of many nonhuman animals, and acts as a nuisance, creating glare, in people’s homes, yards, and neighborhoods. The specific technical standards spelled out in the appendix of definitions, performance standards, types of fixtures, and maintenance standards, are precise and the details are largely appropriate.

2. The essential problem: with a one-sided set of mandates, cost considerations will favor not providing light

The advantage of higher-mounted lighting is that it can illuminate more area with a single lamp. But the disadvantage of this higher-mounted lighting is that it can illuminate more area with a single lamp.

The essential problem at present is lack of balance and lack of guidance on how to deal with tradeoffs. Specifically, the draft Streetlights Policy is limited in its listing of places/reasons streetlights may be provided, and has no details about any of the performance standards for street lighting for safety; but provides a detailed list of performance standards to limit light, provisions that are written as absolute mandates (“shall” language). One of the key ways the two distinct objectives of a) providing light for safety, and b) limiting light trespass and pollution, can be met, is with pedestrian-scale lighting (mounted around 11 to 16 feet in height—similar to what the draft policy defines as streetscape lighting). However, to provide pedestrian-scale lighting along all of Amherst’s roads and streets where we expect or want pedestrians and bicyclists (and scooters and wheelchair users, etc.) to travel is simply cost prohibitive. Most of our lighting will continue to be mounted on utility poles, where it is required (by the utilities) to be higher. Newer lights and bulbs (“luminaires”) can more readily direct light where it is needed, and this is clearly an important technology that informs the current draft policy. However, to provide the continuous illumination along a route that pedestrians and bicyclists need, utility pole mounted lights will need to spread out their light across a longer route. The advantage of higher-mounted lighting is that it can illuminate more area with a single lamp. But the disadvantage of this higher-mounted lighting is that it can illuminate more area with a single lamp. (Yes, those two sentences are intentionally written to be the same thing.)

Largely for this reason, to meet all three objectives—a) providing adequate lighting to illuminate pedestrian and bicyclist routes and crossings, b) avoiding all light trespass, and c) containing costs— all at the same time, will sometimes simply not be possible.

If the streetlights policy is passed at present with its one-sided mandates, the choice when there is a conflict will be to save cost by not providing light.

If the Streetlights Policy is passed at present with its one-sided mandates, the choice when there is a conflict will be to save cost by not providing light.

3. How to achieve the objectives of the draft policy to limit light pollution and trespass, and also protect and enhance pedestrian and bicycle safety (probably too complicated to do this today but bodes well for one more revision)

The proponents of this draft policy have put together an important set of provisions and details. One way to do what is needed is to build on their work, pairing the provisions in this draft with a comparable set of provisions that provide lighting performance standards for safety. Additionally, the Policy could provide guidance for how to how to balance potential tradeoffs among safety, minimization of unnecessary light, and cost.

Specifically what needs to change (slightly expanded from the summary at the start of these comments):

1) The performance standards for protection of the night sky and against light trespass need to be matched by equally strong performance standards for pedestrian and bicycle safety.

I suggest councilors ask for help from a consultant or the UMass Transportation Center to develop the needed specifications for lighting that can protect and encourage pedestrians and bicyclists. To begin, however, from my reading of the documents listed in footnote 2, I have been drafting an initial set of recommended performance standards for pedestrians and bicyclist safety, which are also appropriate for users of mobility aids as well as micro-mobility devices. (There are of course similar specifications for motor vehicle safety; these could likely be provided by the Department of Public Works if desired. An additional thing to keep in mind is that standards and recommendations change as more research is done, so there may need to be provisions for adjustments in the design standard specifications over time.)

 I will put these into a suggested red-lined version of the current Policy that I hope to have ready by this evening’s meeting.

2) The policy needs to shift some of its absolute “shall” language, and to outline processes, including public engagement, that will guide future Town representatives and decision-makers on how to balance potential tradeoffs among safety, minimization of unnecessary light, and cost.

· The policy needs to shift some of its absolute “shall” language

The specifications in the draft policy are good. The problem is the policy language of “shall,” which suggests an absolute mandate with no opportunity for adjustment based on other considerations, except through waiving the policy in a cumbersome process led by the Town Manager and supported by the Director of the DPW or Public Safety.

Here are just two examples where the absolute mandates of the draft policy may conflict with safety:

“All streetlights must be fully shielded”—with shielding defined to include indirect lighting from reflection or refraction. In some places this may limit the ability of tall utility pole lamps to light up extended routes along a bike lane or sidewalk, or across an entire streetscape to light up the sidewalk on the other side.

“No Streetlight… shall create… a Light Trespass”—with Light Trespass defined to mean any light above 0.01 foot-candle, anywhere outside the Public Right-of-Way line. 0.01 foot-candle (US units) is the same as 0.1 lux (international units), and the FHWA’s Pedestrian Lighting Primer (see footnote 2) says that for low-traffic sidewalks the lighting standard is 2 lux. Without very precise pedestrian-scale lighting, it will be extremely difficult, if not impossible, to light a sidewalk adequately at 2 lux while not lighting the abutting property above 0.1 lux at all. Moreover, research shows that a surround ratio—a measure of illuminance (measured in foot-candles or lux) spilling over the edge of a path or roadway—of 80 percent improves the ability of drivers to see pedestrians in and adjacent to the roadway (FHWA 2022: 16).

Instead of “shall” there could be language that would say something like: “where not conflicting with safety performance standards” (which could be spelled out, as suggested above), or “to the extent practicable.”

The Streetlights Policy needs to outline processes, including public engagement, that will guide future Town representatives and decision-makers on how to balance potential tradeoffs among safety, minimization of unnecessary light, and cost.

There are several processes outlined or mentioned by which different members of the public, town staff, or committees, might suggest additional or fewer lights. These are confusing. The clearest and most cumbersome of these is a proposal for the Streetlight policy to be waived. This must be led by the Town Manager and supported by the Director of the DPW or Public Safety. These processes need to be better articulated, and there needs to be clear opportunity for public input, and for the needs of safety to be fully considered.

I am preparing a suggested red-lined version of the current Streetlights Policy that incorporates these points, and also a few examples of where and how I believe tradeoffs could be navigated in different locations. I will attempt to put this together in time for tonight’s meeting but if not, will have it soon thereafter

Thank you very much to all of the Councilors for your careful consideration of this policy.

Eve Vogel

Eve Vogel served on three different town transportation committees for about 10 years total, and chaired the Transportation Advisory Committee’s Complete Streets / Traffic Calming Subcommittee.