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Letter: Franklin Park Action Plan Light Pollution Concerns

Last updated on March 13, 2023

The following letter was sent to Boston Mayor Michelle Wu; Chief of Environment, Energy, and Open Space Rev. Mariama White-Hammond; and Boston Parks and Recreation Commissioner Ryan Woods.

We are writing with concerns about proposals to make significant changes to Franklin Park in the recently released Action Plan. At well over 400 pages, it was too big for us to analyze everything in detail but the recently released highlights from the Franklin Park Coalition alerted us to the proposal to add significant amount of lighting to the paved park paths and clear a large border of understory foliage on the park edges. Both of these suggestions appear to be proposed in the spirit of accessibility, wayfinding and perception of safety however we are concerned that other important aspects are not being taken into account, such as increased light pollution, nighttime park uses that the added lighting would eliminate, added lighting’s effects on the nocturnal creatures that call this urban forest home, as well as noise pollution, effective reduction of the size of the park, and elimination of habitat for park animals and birds that live in this understory habitat.

Increased light pollution

We’d like to remind you that as a city councilor, you sponsored a Dark Skies talk by Kelly Beatty, editor of Sky and Telescope Magazine, at the Arnold Arboretum in July of 2019. We wrote to you after this talk, stating that, “Boston could do so much to minimize light pollution, scale back on unnecessary or incorrectly placed/styled/colored lighting. It would help prevent the very unhealthy environment that bad lighting creates, as warned by the American Medical Association. Further, if the mayor’s office could work toward Boston being a dark sky community, through changing basic lighting requirements in building/zoning and encouraging local organizations and residents to follow the same on their own properties, our backyards and green spaces such as the Emerald Necklace could be turned into places where we could actually see the stars, too.” In 2019, we also reached out to the Emerald Necklace Conservancy and had met with director Karen Mauney-Brodek and corresponded with a few representatives from your office including Brianna Millor, your now Chief of Community Engagement, about implementing dark sky compliant lighting in the Emerald Necklace and elsewhere. We hope that your interest in dark skies as a councilor might inform a different approach to lighting in Franklin Park than what is being proposed now that you are mayor.

We appreciate language in the plan calling for dark-sky friendly lighting, and low-glare fixtures, however acorn lights, which are everywhere in the city, and which people think are attractive and “historic” (though these did not exist when Olmstead designed the park!), are incompatible with dark skies best practices. They emit a lot of side glare and sometimes have no cut off, so the light goes up into the sky instead of down to the ground where it belongs. if the city wants to continue using the acorn fixtures, the parks department should find or create aftermarket caps/shields that can aim the light down and eliminate the glare, or find a different style “historic” light that is truly compliant.

Regarding the scale of lighting we hope you would look at the height of fixtures, not just their quantity or their brightness, as well as the distance between fixtures. The park does not need to be lit up to duplicate daytime lighting, and there are ways to light paths without lighting all of the surrounding areas as well. Take a cue from the Highline Park in New York City, where the lighting is under benches, under railings, all below eye level so that paths are lit but you don’t see the source. The minimal lighting is low power and directed only where you need it, allowing one to enjoy the park at night but still safely navigate the pathways.

Regarding the color of lighting, the plan states it needs to be a “consistent color temperature” (right now lighting ranges from cool blue to warmer tones). This guidance should be changed to a “consistent 2700K warm color temperature,” which is kinder to our eyes and better for community health. There are also wildlife-friendly LEDs, that are wavelength-based instead of color temperature-based.

We understand the concept of adding lighting at the tennis courts or other fields for special events, but the downside could potentially be no good system for turning those lights off when the events have ended. For example, the English High Schools fields are often brightly lit up with no events occurring. A monitoring system would need to be put in place to be sure the lights are turned off when the events are over.

We also understand the request for lighting inside Ellicott Arch at the Williams Street entrance (the one we use). We urge you to light it as minimally as possible. If it is too brightly lit or the lights are aimed in the wrong direction, people can be blinded by the contrast coming in from the darker area of the pathways or from the bulbs themselves. We think this concept would have to be tested first to see how it works, to get it right with different placement options, number of lights, range of brightness, etc. The lighting here can be extremely minimal because it is only needed to contrast slightly against the dark outside of the arch. Color matters as well, if it were red it would not ruin night vision. Being dark skies friendly also means having lighting only where it is absolutely needed. We understand the need to better define park entrances, remove physical barriers such as gates, and have better wayfinding, but the proposed added lighting in a number of areas is (or could be) overkill depending on the exact details of the lighting proposal.

Effects on nocturnal creatures

Adding lights will be detrimental to the significant nocturnal animal habitat in the park, in places where there are no lights now. On the Circuit Loop, Scarborough Pond and its surrounding woods may not be officially part of the Wilderness but this area still functions as a wilderness, with coyotes, raccoons, a number of owl species, amphibians and other nocturnal and nesting birds who will be driven out by or harmed by added lighting. Franklin park’s creatures will be adversely affected by having their habitat lit up through the night when they are most active. A related concern is that the amount of destruction and disruption needed to install all of the electrical infrastructure along the pathways of the park. The park’s ecosystem will suffer from the construction and implementation/use of the new lighting.

Human nighttime park use

The Emerald Necklace Conservancy (ENC) recently launched their campaign “championing sunlight for all Boston parks” (protecting city parks from shadow impingement caused by tall buildings during the day). We raise the parallel issue of protecting these same parks from light pollution at night. Franklin Park, unlike other city parks, has within it an urban forest and it should be treated and maintained as such. We are concerned that the little bit of dark sky we and others enjoy at night in the park might go away once all of these proposed new acorn lights are installed on the pathways. From Mauney-Brodek’s ENC open letter to the mayor regarding the shadow policy:

“…quality and sufficient public space is also an essential basic need. The significance of our public land— the only place one can be without permission or fee— has been at times forgotten. Our public spaces are the only places that we as people can be on the earth, in the air, under the sun. Olmsted called the feeling of being in a park ‘an enhanced sense of freedom.’ You might just call it “freedom”— one little patch of nature that we can inhabit.”

Mauney-Brodek eloquently describes the role Franklin Park, and other city parks, can play in people’s lives during daylight hours, but her statements equally apply to the evening hours, under the moon and the stars.

There are significant human benefits to preserving darkness in the park, such as being able to experience nature at night. We have lived a couple blocks from the park for almost 19 years and frequently take advantage of its proximity to go for walks. Starting with the pandemic, the need to avoid crowds and get out of the house during the lockdown, we ended up establishing a habit of walking there after work almost every day. In the winter, these walks would inevitably happen after dark. Have any of you gone for walks in Franklin Park at night? Have you seen the stars, the raccoons, the fireflies, your shadow cast by a full moon? Have you heard the owls, the coyotes? Franklin Park has been and continues to be an oasis for us and many others. There are few places in the city where you can take an evening walk and experience nature’s sights and sounds in this type of environment.

There are other parks in Boston that are already well or overly lit where people can have a “city park” walking experience. The integrity and character of Franklin Park has been chipped away over time, for other uses like the zoo, golf course, stadium, maintenance yard, hospital, etc., but it still has significant intact natural areas. Adding lighting to a large portion of what is left will detrimentally alter it. The currently unlit portion of Franklin Park is a historic feature worthy of protection. We would hope that the city could help the park, in fact the whole Emerald Necklace, work toward being an Urban Night Sky Place rather than install new lighting in one of the last areas in the city where you might be able to hear nocturnal animals or watch a meteor shower.

Perception of safety vs outreach to educate about the park

The plan repeats a false assumption that visiting the park in the evening is unsafe and states that “Lighting should enhance a sense of security” and that “improving the quality, distribution, and uniformity of lighting can…enhance a sense of safety in the park.” In fact, if you look at crime maps for DorchesterJamaica Plain, and Roxbury, crimes overwhelmingly occur outside the park, not inside. We acknowledge the recent horrific attack on Jean McGuire which received significant press coverage, but what is never covered are the thousands of times people walk in the park and nothing happens. That type of incident is not at all a regular occurrence. Lighting the park will not make the park safer than it already is. Research says there is no correlation between added lighting and added safety. A U.S. National Institute of Justice study concluded: “We can have very little confidence that improved lighting prevents crime.”

Adding lighting is a heavy-handed and expensive solution that might still not resolve the perception of lack of safety. There are so many creative ways to dispel the perception of the park being unsafe. There are ways to work on this problem, to help adjust comfort levels, such as:

  •  share the crime maps, improve and increase communication about the safety of the park
  •  expand Park Ranger hours (we have never seen one in the park for all the years we have spent walking there)
  •  install map boards at every entrance
  •  post QR codes for mobile maps
  • install clear wayfinding signage throughout the park (currently almost nonexistent)
  • offer expansive programs to bring the public into the park, so they can get to know the park

To expand upon the last item, instead of installing a huge system of lights that, once invested in, will never be removed…instead of lighting up most of the park to attempt to dispel a sense of it not being safe (which likely will not change people’s minds once the lighting goes on)…Couldn’t the parks department first launch a mass-education campaign to encourage park use during a range of hours and at different times of year? By hosting programming that assists people in familiarizing themselves with the park in the daytime and experiencing “the park in the dark,” they will feel more comfortable in the park at any hour. The parks department could:
·   outreach to neighboring civic associations and neighbors to offer free programming

  •    hire park ambassadors to run the programs or be onsite in the park to run drop-in activities
  •    encourage people to use flashlights, head lamps, etc.
  •    partner with REI, the Appalachian Mountain Club, astronomy clubs, other orgs to sponsor “outdoorsy” events

The action plan states that park use is minimal during the winter (the darkest time of year in the park), but respondents want activities for “All Weather & Seasons” (56%) and generally want “More Events” (44%). Expanded programming will give neighbors what they want AND help them be more familiar with the park, which will make them feel safer (even though it is already a safe space). Programming ideas:

  •   full moon walks
  •   telescope/naked eye star gazing
  •   meteor shower watch groups
  •   owl walks
  •   general nighttime nature walks
  •   family camping nights
  •   nighttime park sounds walk
  •   nighttime photography
  •   “the park after dark” exercise walks
  •   we could go on!

Clearing the understory at park edges:

Franklin Park wooded acreage has been reduced again and again over the years for other uses. Selectively clearing understory vegetation along the park perimeter by 15-20’ in order to increase porosity and views into the park significantly reduces the amount of bird and other understory creature habitat, and allows city lights and noise to pour into the park. Again repeating this perception of lack of safety, clearing the underbrush to create “views” is supposed to increase a sense of comfort, but it destroys the point of having a park within which we can surround ourselves with nature. 70% of Action Plan survey respondents identified access to nature as their most appreciated thing about the park. Again from the ENC open letter to the mayor:

“Frederick Law Olmsted saw our future when he wrote 150 years ago that city residents need access to places where they ‘may stroll for an hour, seeing, hearing, and feeling nothing of the bustle and jar of the streets, where they shall, in effect, find the city put far away from them’.”

Letting the outside city noise infiltrate the park diminishes the feeling of being in nature and being able to get away from the busy city. This is already apparent on the American Legion side of the park where there is no vegetation boundary, just taller trees, and the noise of car engines and radios carries all the way across the golf course to the opposite side of the park and beyond the park borders into the surrounding neighborhood. The understory not only provides habitat, it provides a buffer. We heartily agree that invasives are a huge problem within the edge (and elsewhere), and need to be dealt with, but please replace them with natives, don’t eliminate the underbrush altogether.

Thank you for your attention to these important matters. Please feel free to reach out to us if you have any questions or want to talk further.

Jennifer Uhrhane and Jonathan McCurdy


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