June 18, 2026
City of San Rafael Mayor and City Council
1400 Fifth Avenue
San Rafael, CA 94901
Re: Request to Exclude Shoreline Path/Starkweather Path Lighting from the Canal Neighborhood Active Transportation Enhancement Project
Dear Mayor and Members of the City Council:
I am writing to express concern regarding the proposed installation of lighting along the Shoreline Path/Starkweather Path due to the potential impacts on birds and sensitive shoreline habitats.
Point Blue Conservation Science has been conducting bird monitoring and ecological research in San Francisco Bay wetlands and shorelines for several decades. We have led or contributed to many of the region's long-term monitoring programs, including surveys of tidal marsh birds, shorebirds, and waterfowl, and have worked closely with local, state, and federal entities to inform wetland restoration, species recovery, and habitat management throughout the estuary.
I submit these comments in my capacity as San Francisco Bay Program Leader for Point Blue Conservation Science. For more than two decades, I have worked on tidal marsh bird conservation, monitoring, and research in the estuary. I have led monitoring for secretive marsh birds since 2005, led the development of the regional tidal marsh bird monitoring framework, served on the U.S. Fish and Wildlife Service Tidal Marsh Recovery Plan Implementation Team, and am a leading author of the San Francisco Bay State of the Birds (www.sfbaystateofthebirds.org).
The shoreline Path is directly adjacent to tidal marsh, mudflat, and open-water habitats that support a diverse community of resident and migratory birds. These habitats provide important breeding, foraging, and refuge areas for at-risk tidal marsh birds, as well as migratory shorebirds, waterfowl, and other waterbirds that use San Francisco Bay as a critical stopover and wintering area along the Pacific Flyway. San Francisco Bay is recognized as a “Wetland of International Importance” under the Ramsar Convention on Wetlands underscoring the importance of protecting habitat quality and ecological function throughout the estuary.
A substantial body of scientific literature demonstrates that artificial light at night can negatively affect birds by altering behavior, disrupting migration, reducing use of otherwise suitable habitat, and increasing predation risk (Longcore and Rich 2004, Van Doren et al. 2017, McLaren et al. 2018).
The tidal marshes that border parts of the path provide habitat for the California Ridgway’s Rail, a federally endangered species whose population is already critically low (USFWS 2014). Artificial lighting may increase exposure of Ridgway’s Rails and other marsh birds to predators that forage mostly at night though we are unaware of any studies that have directly evaluated the effects of artificial nighttime lighting on California Ridgway’s Rails specifically.
Shorebirds and waterbirds using adjacent mudflats and open waters may also alter their foraging and roosting behavior in response to nighttime lighting, potentially reducing the value of these habitats (Gaston et al. 2013). Minimizing nighttime disturbance and preserving dark marsh environments are consistent with regional conservation objectives aimed at protecting and recovering these species.
Importantly, the Shoreline Path is currently unlit and closed from sunset to sunrise.
The proposed project would therefore introduce a new source of nighttime illumination onto a shoreline that presently provides relatively dark conditions adjacent to sensitive wildlife habitat. Maintaining dark shoreline environments is increasingly recognized as an important conservation practice for protecting wildlife and preserving ecological function (International Dark-Sky Association 2023).
If the City determines that installation of lighting is unavoidable, potential impacts to birds and adjacent bayland habitats could be reduced by limiting lighting to the proposed low-profile fixtures (approximately 3.5 feet in height), minimizing illumination levels to the extent necessary for public safety, and ensuring that all fixtures are fully shielded and directed away from tidal marsh, mudflat, and openwater habitats. If implemented together, these three measures would help reduce light spill into sensitive habitats and lessen the negative impacts to wildlife while still illuminating the path.
Given the ecological importance of these marsh and bay habitats, the international significance of San Francisco Bay for migratory birds, and the presence of sensitive species such as the California Ridgway’s Rail, I respectfully recommend that the City remove the Shoreline Path/Starkweather Path lighting component from the project and maintain existing nighttime conditions along this shoreline.
Thank you for your consideration.
Sincerely,
Julian Wood, San Francisco Bay Program Leader
References
Gaston, K.J., Bennie, J., Davies, T.W., and Hopkins, J. 2013. The ecological impacts of nighttime light pollution: a mechanistic appraisal. Biological Reviews 88:912–927.
International Dark-Sky Association. 2023. Principles for Responsible Outdoor Lighting and Wildlife Protection.
Longcore, T., and Rich, C. 2004. Ecological light pollution. Frontiers in Ecology and the Environment 2:191–198.
McLaren, J.D., Buler, J.J., Schreckengost, T., Smolinsky, J.A., Boone, M., van Loon, E., Dawson, D.K., and Walters, E.L. 2018. Artificial light at night confounds broad-scale habitat use by migrating birds. Ecology Letters 21:356–364.
USFWS. 2014. Recovery Plan for Tidal Marsh Ecosystems of Northern and Central California. U.S. Fish and Wildlife Service, Sacramento Fish and Wildlife Office, Sacramento, California.
Van Doren, B.M., Horton, K.G., Dokter, A.M., Klinck, H., Elbin, S.B., and Farnsworth, A. 2017. High-intensity urban light installation dramatically alters nocturnal bird migration. Proceedings of the National Academy of Sciences 114:11175–11180.