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Home My WebLink AboutStaff Report 2504-4532CITY OF PALO ALTO CITY COUNCIL Monday, November 10, 2025 Council Chambers & Hybrid 5:30 PM Agenda Item 8.REINTRODUCED FIRST READING: Adoption of an Ordinance Updating Palo Alto Municipal Code (PAMC) Section 18.40.250 (Lighting) of Chapter 18.40 (General Standards and Exceptions) and Amending Chapters 18.10, 18.12, 18.28, and Section 18.40.230 of Title 18 (Zoning) to Adopt New Outdoor Lighting Regulations; CEQA Status — Exempt pursuant to CEQA Guidelines Section 15308 (Actions for Protection of the Environment) Public Comment, Staff Presentation 7 1 1 2 City Council Staff Report From: City Manager Report Type: ACTION ITEMS Lead Department: Planning and Development Services Meeting Date: November 10, 2025 Report #:2504-4532 TITLE REINTRODUCED FIRST READING: Adoption of an Ordinance Updating Palo Alto Municipal Code (PAMC) Section 18.40.250 (Lighting) of Chapter 18.40 (General Standards and Exceptions) and Amending Chapters 18.10, 18.12, 18.28, and Section 18.40.230 of Title 18 (Zoning) to Adopt New Outdoor Lighting Regulations; CEQA Status — Exempt pursuant to CEQA Guidelines Section 15308 (Actions for Protection of the Environment) RECOMMENDATION Staff recommend the City Council adopt the Draft Ordinance updating Palo Alto Municipal Code (PAMC) Section 18.40.250 (Lighting) of Chapter 18.40 (General Standards and Exceptions) and Amending Chapters 18.10, 18.12, 18.28, and Section 18.40.230 of Title 18 (Zoning) to adopt new outdoor lighting regulations. EXECUTIVE SUMMARY The draft Lighting Ordinance (Attachment A) implements part of one of the City Council’s priorities (No. 18, Council consideration of an ordinance implementing Bird Safe Glass & Wildlife Light Pollution Protections standards) and is consistent with Comprehensive Plan policies (including Policies N-1.9, N-3.3, and N-7.5). The draft ordinance, which has been modified based on City Council direction on April 7, 2025, aims to reduce light pollution and align with Dark Sky principles in order to increase the health and well-being of Palo Alto residents, protect wildlife and natural ecosystems, and reduce light pollution. The City Council’s direction at the April hearing aligned with the Planning and Transportation Commission (PTC) recommendations from October 2024, including requiring that new standards apply to replacement of existing lighting; allowing additional exceptions; and increasing efforts to raise awareness, which may help reduce the number of complaints and reliance on code enforcement. In addition, the City Council requested that requirements be included for already- installed existing lighting to comply with the new lighting standards after a set time period. 7 1 1 2 The City does not have sufficient resources to proactively enforce the ordinance; staff will respond to egregious violations as capacity allows and will rely on outreach and community- based compliance measures to support implementation. BACKGROUND 1 The organization publishes guidance for communities seeking to achieve a “dark sky” and decrease light pollution. The framework focuses on principles, which have been incorporated into the proposed ordinance: 1 Link to the DarkSky International Website: https://darksky.org/who-we-are/advocates 7 1 1 2 4. Controlled: Use light only when it is needed. Use controls such as timers or motion detectors to ensure that light is available when it is needed, dimmed when possible, and turned off when not needed. 5. Warm-colored: Use warmer color lights where possible. Limit the amount of shorter wavelength (blue-violet) light to the least amount needed. Previous City Council Discussion On April 7, 2025,3 staff presented its recommendation for the Lighting Ordinance update, which differed from the Planning and Transportation Commission’s recommendation of October 30, 2024. Staff clarified that its recommendations primarily centered around concerns regarding impacts on enforcement and implementation once adopted. After deliberation, the City Council directed staff to return with several modifications, including requiring that new standards apply to replacement of existing lighting; allowing additional exceptions; and increasing efforts to raise awareness. These modifications aligned with most of the PTC recommendations and included requirements to be applied to all existing lighting, similar to the City of Brisbane. The City Council motion and staff analysis is provided below. ANALYSIS On April 7, 2025, the City Council directed staff to revise the draft ordinance for greater consistency with the recommendations made by the Planning and Transportation Commission in October 2024. The City Council’s motion items are italicized below, and staff descriptions on how each was incorporated into the draft ordinance follow each element of the motion: MOTION: A. Ensure protections in the existing code are not eroded for existing outdoor lighting in all zoning districts. a. Retain the Requirements and Guidelines that the current municipal code provides to riparian ecosystems section 18.40.140. No revisions needed as the updated ordinance provides equivalent or greater protection from light pollution compared to the existing outdoor lighting requirements. Additionally, the existing provisions and requirements in PAMC 18.40.140 will remain until the Stream Corridor Protection Ordinance Update is adopted. B. Require this ordinance apply to all new or replacement outdoor lighting consistent with the Planning and Transportation Commission (PTC) motion of October 30th to include: 3 Link to the City Council agenda for the public hearing on April 7, 2025 (Item #17): https://cityofpaloalto.primegov.com/Portal/Meeting?meetingTemplateId=16024 7 1 1 2 a. Installation of new outdoor lighting, replacement of existing outdoor lighting fixtures, or changing the lighting type or system; Incorporated in Section 18.40.250(c). The language from the motion was added to the applicability section. b. for replacement lighting fixtures on buildings and structures, develop a hardship exception provision that would consider technical feasibility or financial burden to only apply to replacements on existing buildings and structures; and Incorporated in Section 18.40.250(j)(2). An exception can be requested if implementation of the lighting requirements more than doubles the cost of the project. c. any existing nonconforming lighting after 10 years for residential and 5 years for nonresidential shall remain extinguished until brought into compliance with this ordinance. Incorporated in Section 18.40.250(l). The deadline for existing lighting to comply with the new requirements is five years from the effective date of the ordinance for nonresidential zoning districts, and 10 years for residential and mixed-use zoning districts. Any existing lighting that has not been brought into compliance with the Code by these deadlines must remain extinguished (off) until it meets the new lighting standards. C. Existing luminaires that have the technical capacity to be adjusted to comply with the ordinance without a need to change the fixture should comply within two (2) years of the effective date of the ordinance (i.e: fixtures that have existing dimmers, adjustable directionality, timers, Correlated Color Temperature adjusters, motion sensors, etc.). Incorporated in Section 18.40.250(l)(2). The deadline for existing lighting to comply through use of existing features is two years from the ordinance's effective date. That lighting will be required to meet the new standards, with the exception of the shielding requirements. D. Amend Section (4)(A) to include specific application of the curfew to all new, replacement, and existing outdoor luminaires. a. Citywide and Holiday lighting curfew of midnight. Incorporated in Sections 18.40.250(d)(4) and 18.40.250(e)(4). The lighting curfew provision was revised to extend the turn-off time of all outdoor lighting to 12:00 7 1 1 2 a.m. Additionally, the seasonal lighting exception language was revised to explicitly state when such lighting is subject to extinguishment. E. Implement the October 30th PTC motion regarding light trespass to change the light trespass from 0.5 to 0.1 foot candles at every reference throughout the ordinance. Incorporated throughout the ordinance. F. Incorporate into Section 1.B. Findings and Declarations, and Section 2 (a) Purpose, the Five Principles for Responsible Outdoor Lighting. One of the sections should include the full language of the principles. Incorporated (Section 1B of the ordinance, and Section 18.40.250(a)(1)). G. Develop an exception for special security concerns. An exemption has been incorporated in the draft ordinance (Section 18.40.250(d)(7)) to address this direction, however without use of “special security concerns.” See below for further discussion of the specific approach presented. H. Staff to return with recommendations on compliance mechanisms that would reduce the need for code enforcement – such as self-certification under business licenses, education through Utilities inserts, and potential adoption of a tool similar to Brisbane’s Good Neighbor Letter. Potential measures are explained below for the City Council consideration, along with the pros and cons for each measure. Exception for Special Security Concerns During the April hearing, the City Council heard concerns from a community member about how the proposed new lighting standards might impact security, especially in their neighborhood along Edgewood Drive. A speaker noted that less or limited lighting could worsen existing security concerns for property owners in the neighborhood. In response, the City Council asked staff to look into allowing an exception for properties with heightened security concerns. Staff worked with the City’s Police Department and reviewed crime information from the past year for areas near the San Francisquito Creek. While the information showed that crimes and calls for service do occur in this area, they were not significantly higher in the specific residential neighborhood mentioned compared to other areas of the City. The Police Department also confirmed that the City currently does not have any areas identified as having 7 1 1 2 special concerns due to high crime rates, and there are not areas in Palo Alto that they would characterize as “high crime.” While crime data do not support the designation of specific areas as high security risk zones, staff recognize some residents may have heightened perceptions of safety concerns based on local conditions or experiences. Neighbor Letter Template: A letter template modeled on tools used by the City of Brisbane and DarkSky International could allow residents to inform neighbors about the ordinance and encourage voluntary compliance. While this may reduce initial complaints to the City, it relies on voluntary action and may lead to disputes or unprioritized reports. Educational Materials: Staff will develop outreach materials, including online content, printed handouts, and utility bill inserts, to raise awareness about the new requirements. This approach aims to reduce inadvertent non-compliance through public education but has no direct enforcement effect and depends on public engagement. Affidavit Letter: Staff considered requiring applicants and property owners to sign an affidavit acknowledging awareness of the lighting requirements during the permit process. However, this approach would duplicate information already reviewed as part 7 1 1 2 of plan review and introduce additional regulatory steps to the permitting process, and is therefore not recommended. POLICY IMPLICATIONS FISCAL/RESOURCE IMPACT STAKEHOLDER ENGAGEMENT 7 1 1 2 Valley Audubon Society and Sierra Club Loma Prieta Chapter to solicit their input on the proposed ordinances. 7 1 1 2 ENVIRONMENTAL REVIEW ATTACHMENTS APPROVED BY: *** NOT YET APPROVED *** 1 0160151_20250821_ay16 Ordinance No. _____ Ordinance of the Council of the City of Palo Alto Repealing and Replacing Section 18.40.250 (Lighting) of Chapter 18.40 (General Standards and Exceptions) and Amending Chapters 18.10, 18.12, 18.28 and Section 18.40.230 of Title 18 (Zoning) of the Palo Alto Municipal Code to Adopt New Outdoor Lighting Regulations The Council of the City of Palo Alto ORDAINS as follows: SECTION 1. Findings and Declarations. The City Council finds and declares as follows: A. The term “dark sky” generally refers to achievement of signiﬁcant reduc on in light pollu on so that the sky returns or becomes closer to its natural nigh me darkness. B. Adhering to Dark Sky principles, which promote responsible outdoor ligh ng prac ces, can signiﬁcantly reduce light pollu on and mi gate its harmful eﬀects. These principles emphasize using light only if it is needed, direc ng so that it falls only where it is needed, having ligh ng only when it is necessary and no brighter than necessary, and using warmer lights. C. On January 29, 2024, the City Council selected four City Council priori es, one of which is the Climate Change & Natural Environment – Protec on & Adapta on, and included an objec ve to “approve a bird safe glass and wildlife light pollu on protec ons ordinance.” D. On February 14, 2024, and July 18, 2024, the Architectural Review Board conducted study sessions and provided feedback on the concepts of the DarkSky regula ons and dra ordinance. E. On August 14, 2024, the Planning and Transporta on Commission reviewed the dra ordinance, provided feedback and recommended that staﬀ return with more informa on, con nuing the hearing to a date uncertain. F. On October 30, 2024, the Planning and Transporta on Commission recommended that City Council adopt the ordinance. G. The ordinance aligns with Dark Sky principles and is intended to reduce light pollu on at night, protec ng wildlife and suppor ng a sustainable and resilient community. SECTION 2. Section 18.40.250 (Lighting) of Chapter 18.40 (General Standards and Exceptions) of Title 18 (Zoning) of the Palo Alto Municipal Code is repealed in its entirety and replaced with a new Section 18.40.250 (Lighting) to read as follows: 18.40.250 Lighting (a) Purpose. The intent of this section is to establish exterior lighting standards to reduce light pollution. Exterior lighting of parking areas, pathways, and common open spaces, including fixtures on building facades and free-standing lighting should aim to: *** NOT YET APPROVED *** 2 0160151_20250821_ay16 (1) Reduce light pollution and its adverse effects on the environment, wildlife habitat, and human health through implementing Dark Sky Principles of responsible outdoor lighting that are useful, targeted, low level, controlled, and warm colored; (2) Minimize the visual impacts of lighting on abutting or nearby properties and from adjacent roadways; (3) Provide safe and secure access on a site and adjacent pedestrian routes; (4) Achieve maximum energy efficiency; and (5) Complement the architectural design of the project. (b) Definitions. For purposes of this chapter, the following words and phrases are defined as follows: (1) “Correlated Color Temperature” or “Color Temperature” means a specification of the color appearance of the light emitted by a light source, measured in Kelvin (K). Warmer color temperatures are a lower number, and cooler color temperatures are a higher number. (2) “Fully Shielded” means a luminaire constructed and installed in such a manner that all light emitted, either directly from the lamp or a diffusing element, or indirectly by reflection or refraction from any part of the luminaire, is projected below the horizontal plane extending from the bottom of the lamp. (3) “Glare” means light entering the eye directly from a luminaire or indirectly from reflective surfaces that causes visual discomfort or reduced visibility to a person. (4) “Lamp” means, in generic terms, a source light, often called a “bulb” or “tube.” Examples include incandescent, fluorescent, high-intensity discharge (HID) lamps, and low-pressure sodium (LPS) lamps, as well as light-emitting diode (LED) modules and arrays. (5) “Light pollution” means the material adverse effect of artificial light, including, but not limited to, glare, light trespass, sky glow, energy waste, compromised safety and security, and impacts on the nocturnal environment, including light sources that are left on when they no longer serve a useful function. (6) “Lumen” means the common unit of measure used to quantify the amount of visible light produced by a lamp or emitted from a luminaire (as distinct from “Watt,” a measure of power consumption). (7) “Luminaire” means outdoor illuminating devices, lamps, and similar devices, including solar powered lights, and all parts used to distribute the light and/or protect the lamp, permanently installed or portable. (8) “Seasonal ligh ng” means ligh ng installed and operated in connec on with holidays or tradi ons within the me period speciﬁed in Sec on 18.40.250(d)(4). String *** NOT YET APPROVED *** 3 0160151_20250821_ay16 ligh ng used outside these periods is not considered seasonal ligh ng and shall be subject to requirements in Sec on 18.40.250(f)(6). (9) “String lighting” means light sources connected by free-strung wires or inside of tubing resulting in several or many points of light. (c) Applicability. Except as otherwise provided in subsections (d) and (e)(4)(A) below, the outdoor lighting standards and guidelines set forth in this Section shall apply to the following projects: (1) All newly constructed structures and buildings; or (2) Structures or buildings proposing a Substantial Remodel, as defined in Section 16.14.070; or (3) If a building permit is required: New installation of outdoor luminaires, replacement of existing outdoor luminaires, or modifications to the lighting type or system. (4) All existing outdoor light fixtures installed prior to the effective date of this ordinance shall conform to the provisions of this ordinance according to the compliance schedule set forth in Section 18.40.250(l). (d) Exemptions. The following types of lighting are exempt from the lighting requirements of the section: (1) Illuminated street numbers; (2) Temporary construction or lighting for emergency personnel; (3) Lighting authorized by a special event, special or temporary use permit; (4) Seasonal lighting, subject to extinguishment at 12:00 a.m., during the period of October 15 through January 15 of each year; (5) Lighting for Airport Operations. Nothing in this section shall be interpreted to restrict, limit, or otherwise regulate lighting that, in the reasonable judgment of the Airport Manager, is prudent or necessary for airport operations, airport safety, or air navigation in connection with operations at the Palo Alto Municipal Airport; or (6) Lighting for Emergency Shelters. Lighting for emergency shelters shall be subject to PAMC 18.14.060. (7) Single family residential sites adjacent to San Francisquito Creek and fronting on Edgewood Drive if the portion of the site subject to a permanent easement in favor of the Santa Clara Valley Water District (or its successor in interest) for flood control purposes is reconfigured after January 1, 2002. These sites shall be subject to the requirements under Section 18.40.250(e)(4)(A). (e) Lighting Standards. (1) Shielding *** NOT YET APPROVED *** 4 0160151_20250821_ay16 (A) All outdoor lighting shall be fully shielded and directed to avoid light trespass. No lighting shall trespass more than 0.1-foot candle as measured at the property line. (B) Exceptions for shielding requirements shall be applied to the following types of lighting: (i) Low voltage landscape uplighting used to illuminate fountains, shrubbery, trees, and walkways, outdoor art or public monuments provided that they use no more than a 10-watt incandescent bulb or LED equivalent or emit no more than 150 lumens. These luminaires may not direct light towards the public right-of-way; (ii) Sidewalk-facing ligh ng for zero lot line developments, provided the luminaires are motion-activated and automatically extinguish within five minutes without further activation; or (iii) String lighting pursuant to Section 18.40.250(f)(5). (2) Parking Lot Lighting Height. (A) Exterior lighting fixtures shall be mounted less than or equal to 15 feet from grade to top of fixture in parking lots in residential development and 20 feet in parking lots with commercial and mixed-use development. (3) Illumination Level and Color Temperature (A) All light sources shall have a correlated color temperature of 2,700 Kelvin or less. (B) The maximum outdoor light intensity on a site shall not exceed an average value of 5 foot-candles. (4) Lighting Control. (A) Lighting Curfew. Unlike other provisions in this section, the Lighting Curfew shall apply to all outdoor luminaires for new and existing buildings and structures, unless otherwise approved. All outdoor lighting shall be fully extinguished or be motion sensor operated by 12:00 a.m., two hours after the close of business, or when people are no longer present in exterior areas, whichever is later. (B) All lighting activated by motion sensor shall be set up to extinguish after no more than five minutes without further activation. (C) All lighting shall be automatically extinguished using a control device or system when there is sufficient daylight available, except for lighting under canopies or lighting for tunnels, parking garages, or garage entrances. (D) Exceptions for Lighting Control. *** NOT YET APPROVED *** 5 0160151_20250821_ay16 (i) Any lighting at building entrances, parking areas, walkways, and driveways area; (ii) Outdoor pathway lights that emit 25 lumens or less; or (iii) Lighting that illuminates a pedestrian pathway (examples include bollard, in-place step, or building mounted), provided that such lighting is a maximum height of four (4) feet above the pathway and fully shielded. (f) Special Purpose Lighting. The standards in this section shall prevail over any conflicting standard in subsection (e). (1) Low Density Residential Lighting. In addition to the lighting standards in the section, the following lighting requirements shall be applicable to projects in R-1, R-2, RE, RMD, NV- R1, or NV-R2. (A) When abutting any residential use, no spillover of lighting to adjacent properties shall be allowed. (B) A maximum of 1,260 lumens shall be allowed for each fully shielded outdoor lighting. No more than 420 lumens shall be allowed for permitted non-shielded outdoor lighting. (C) Skylights shall limit illuminance and glare during night hours. Glare shall be mitigated through the use of translucent glass, shading systems, and interior light placement. Skylights shall not use white glass. (D) Height for Recreational and Security Lighting. Free-standing lighting shall be a maximum of twelve feet (12’) in height for those that were installed on or after March 11, 1991. (2) Athletic Facilities Lighting. Outdoor athletic facilities shall conform to the following standards: (A) Field lighting is provided exclusively for illumination of the surface of play and viewing stands, and adjacent proximity areas for public safety. (B) Illumination levels shall be adjustable based on the task (e.g., active play vs. field maintenance). (C) Off-site impacts of the lighting will be limited to the greatest practical extent possible. (D) Lights shall be extinguished by 10:30 p.m. except when the facilities are being used for active play and maintenance before or after permitted events, and the lights are equipped with a timer. (E) Timers that automatically extinguish lights shall be installed to prevent lights being left on accidentally overnight. *** NOT YET APPROVED *** 6 0160151_20250821_ay16 (3) Automobile Service Station Lighting (A) Lighting fixtures in the ceiling of canopies shall be fully recessed or mounted directly to the underside of the canopy. All luminaires shall be located so that no lighting is directed towards the adjoining property or public rights-of-way. (B) Luminaires are not permitted on top of the canopy fascia. (C) The maximum light intensity under the canopy shall not exceed an average foot- candle of 12.5, when measured at finished grade. (D) No free-standing lighting shall be higher than 15 feet above finished grade. (E) The canopy fascia shall not be illuminated. (4) Outdoor Space Above Ground Floor. These requirements apply to all outdoor spaces located above ground level, including, but not limited to, roo op gardens, roo op restaurants or bars, balconies, and decks. (A) Any lighting shall be shielded from public views and any luminaires shall be fully shielded and no uplighting shall be permitted. (B) Lights shall be dimmable to control glare and placed on timers to turn off after 10:00 p.m. or as permitted pursuant to Section 18.40.250(e)(4)(D) (C) No light trespass shall be allowed more than 0.1 foot-candle as measured beyond the perimeter of the roof deck or other outdoor space above the ground floor. (5) String Lighting. (A) String lighting color temperature shall not exceed 2,700 Kelvin and no individual lamp that is part of a string lighting installation shall exceed a rating of 42 lumens. No string lighting shall be blinking, flashing, or chasing. (B) For commercial and mixed-use areas, string lighting shall be limited to designated outside dining or display areas or common open space (i.e. courtyard or patio). (6) Parklets. Lighting for any parklets shall comply with the lighting standards established in the Permanent Parklet Program. (g) Prohibited Lighting. The following types of lighting are prohibited except when used by emergency service personnel during an emergency: (1) Outdoor lighting that blinks, flashes, or rotates; or (2) Searchlights, aerial lasers, or spotlights. (h) Lighting for Signs. See Chapter 16.20 for lighting requirements for signs. (i) Additional Provisions and Conflict Precedence. Lighting required by the Building Code, Fire Code, or state or federal law shall additionally comply with the requirements of this section, *** NOT YET APPROVED *** 7 0160151_20250821_ay16 unless these requirements necessarily conflict with the aforementioned Codes and laws. In the event of a conflict, the standards in the applicable Codes and laws shall prevail. (j) Hardship Exceptions. The Director may grant an exception from the requirements in Section 18.40.250, if a project applicant provides evidence demonstrating one of the following hardships: (1) Implementation of the lighting requirements in this ordinance would impair the historical integrity and character-defining features of the building and create an adverse impact to the building’s historical, architectural, and cultural significance; or (2) Implementation of the lighting requirements in this ordinance would more than double the cost of the project. This exception shall apply only for replacement of existing outdoor luminaires or changing the lighting type or system that requires a building permit. (k) Public Facilities. Public Facilities, including City-owned and operated facilities, shall comply with the outdoor lighting standards of this Section to the extent feasible. The Director may grant adjustments to any applicable lighting standards for such facilities if the adjustment is necessary for the efficient operation, maintenance, or safety of the facility, or to ensure public safety and security; and is consistent with the overall intent and purpose of this Section. A written request for an adjustment, including supporting documentation, shall be submitted and shall be reviewed according to the applicable review procedures in PAMC Section 18.77 associated with the proposed development. (l) Existing Nonconforming Lighting. (1) Within two years of [the effective date of this ordinance]: Where existing outdoor luminaires have the ability to adjust (through existing dimmers, directional adjustability, timers, etc.), the requirements under Section 18.40.140(e), except for the shielding requirements under the subsection 18.40.140(e)(1), shall apply. (2) For all existing outdoor luminaires, the requirements under Section 18.40.140(e) shall apply within the following timeframes from [the effective date of this ordinance]: (A) Residential and Mixed Use Zoning Districts: Within ten years. (B) Nonresidential Zoning Districts: Within five years. (3) Any nonconforming lighting still in place after the compliance deadline shall remain extinguished at all times until they are brought into compliance. SECTION 3. Subsection (e) of Section 18.40.230 (Rooftop Gardens) of Chapter 18.40 (General Standards and Exceptions) of Title 18 (Zoning) of the Palo Alto Municipal Code is amended to read as follows (additions underlined; deletions struck-through): (e) Any lighting shall be shielded from public views and have full cutoff fixtures that cast downward-facing light, or consist of low-level string lights; no up-lighting is permitted. Lights shall be dimmable to control glare and placed on timers to turn off after 10:00 p.m. *** NOT YET APPROVED *** 8 0160151_20250821_ay16 Photometric diagrams must be submitted by the applicant to ensure there are no spillover impacts into windows or openings of adjacent properties.For lighting requirements, refer to Section 18.40.250. SECTION 4. Subsection (g) of Section 18.10.040 (Development Standards) of Chapter 18.10 (Low Density Residential (RE, R-2 and RMD) Districts) of Title 18 (Zoning) of the Palo Alto Municipal Code is amended to read as follows (additions underlined; deletions struck-through): (g) Lighting in R-2 District In the R-2 district, recreational and security lighting shall be permitted only so long as the lighting is shielded so that the direct light does not extend beyond the property where it is located. Free- standing recreational and security lighting installed on or later than March 11, 1991, shall be restricted to twelve feet (12') in height. For lighting requirements, refer to Section 18.40.250. SECTION 5. Subsection (k) of Section 18.12.040 (Site Development Standards) of Chapter 18.12 (R-1 Single-Family Residential District) of Title 18 (Zoning) of the Palo Alto Municipal Code is amended to read as follows (additions underlined; deletions struck-through): (k) Lighting Recreational and security lighting shall be permitted only so long as the lighting is shielded so that the direct light does not extend beyond the property where it is located. Free-standing recreational and security lighting installed on or later than March 11, 1991 shall be restricted to twelve feet (12') in height. Direct light from outdoor fixtures shall only fall on the walls, eaves, and yard areas of the site on which it is located. Outdoor fixtures shall have lens covers or reflectors that direct the light away from the neighboring properties. For lighting requirements, refer to Section 18.40.250. SECTION 6. Subsection (n) of Section 18.28.270 (Additional OS District Regulations) of Chapter 18.28 (Special Purpose Districts) of Title 18 (Zoning) of the Palo Alto Municipal Code is amended to read as follows (additions underlined; deletions struck-through): (n) Light and Glare Exterior lighting should be low-intensity and shielded from view so it is not directly visible from off-site. The light emitted from skylights shall be minimal during the night hours. Utilizing treatments such as translucent glass, shading systems, and interior light placement can reduce the night glare. Skylights shall not use white glass. For lighting requirements, refer to Section 18.40.250. SECTION 7. If any section, subsection, clause or phrase of this Ordinance is for any reason held to be invalid, such decision shall not affect the validity of the remaining portion or sections of the Ordinance. The Council hereby declares that it should have adopted the Ordinance and each section, subsection, sentence, clause or phrase thereof irrespective of the fact that any one or more sections, subsections, sentences, clauses or phrases be declared invalid. *** NOT YET APPROVED *** 9 0160151_20250821_ay16 SECTION 8. The Council finds that this project is exempt from the provisions of the California Environmental Quality Act (“CEQA”), pursuant to Section 15061 of the CEQA Guidelines, because it can be seen with certainty that there is no possibility that the ordinance will have a significant effect on the environment and Section 15308, as an action by a regulatory agency to protect the environment. SECTION 9. This ordinance shall be effective on the thirty-first day following its adoption. SECTION 10. This Ordinance shall not apply to any project application deemed complete prior to the effective date of this Ordinance. INTRODUCED: PASSED: AYES: NOES: ABSENT: ABSTENTIONS: NOT PARTICIPATING: ATTEST: ____________________________                     ____________________________ City Clerk                                                             Mayor APPROVED AS TO FORM:                                    APPROVED: ____________________________                     ____________________________ Assistant City Attorney                                    City Manager                                                                             ____________________________                                                                    Director of Planning & Development Services Have you heard? The City of Brisbane passed a “Dark Sky Ordinance” that regulates outdoor lighting. You may not be aware of this, but your lights are: too bright shining in our window interfering with our sleep ________________ ________________ Please consider: directing your lights downward shielding the lamp using a lower wattage bulb using a “warmer” color temperature using motion sensor and/or timer ________________ I would be willing to help with the cost and/or implementation of changes. In addition to helping us out, these actions can help bring you into compliance with the City’s ordinance, reduce light pollution, and improve the environment. Thanks so much for your time and understanding! - your concerned neighbor Learn more at brisbaneca.org/darksky Adapted by OSEC from darksky.org/resources/what-is-light-pollution/light-pollution-solutions/lighting/my-neighbors-lighting/ Dear Neighbor... Shielding reduces glare that can be dangerous and unsafe. Glare can be blinding and create harsh shadows where “bad guys” can hide. Shielded lighting provides real security, not just the illusion of security, which I think we both want for our families and friends. There are several other ways to improve lighting, save money, and still be safe. One is using motion sensors, which alert you if someone is in your yard after dark and have the added benefit of reducing your electric bills by keeping the lights off when they’re not needed. Timers are another way to save money because these devices turn off your lights when they’re not needed, for example, when you retire for the night. [Date] Dear [insert neighbor’s name], I’m your neighbor [insert your name] at [address], and I would love to talk with you about good outdoor lighting. I notice that you have installed outdoor lights on your property, and I applaud your desire to help improve our neighborhood. You may not have realized that some of your lights are a bit too bright and shine in [pick areas as they apply: our bedroom window, the backyard, into our house etc.] and interfere with our [sleep, hobbies, view of the sky, etc.]. I don’t wish to tell you what to do with your home, but I’m hoping we can openly discuss this and come to a compromise that fulfills and respects everyone’s needs. Please understand I’m not asking you to remove the lights, but perhaps make subtle changes that will work for everyone. One idea would be redirecting the light by shielding the fixtures so that they are even more effective. Unshielded lamps create dangerous glare — this glare causes harsh shadows which can blind you to real, hidden hazards such as unwanted visitors (see pictures below). On the other hand, shielded lighting provides real security (not just the illusion of security) which I think we both want for our homes. As an extra benefit, shielding a lamp usually involves a lower wattage bulb, which would be a money-saver on your electric bill. There are several other ways to improve lighting, save money, and still be safe. One is using motion sensors, which alert you if someone is in your yard after dark, and also reduce your electric bills by keeping the lights off when not needed. Timers are another way to save money, since they can automatically turn off your outdoor lights when you go to bed. Thank you so much for your time and understanding! I would love to talk with you about how I can help, and how lighting changes can benefit your safety, budget, and the night sky. Sincerely, [your name] [contact info] Shielded lights protect the night. Protect the night Preserving and restoring the natural nighttime environment is more urgent than ever. Light pollution continues to grow at an alarming rate, harming our health, damaging the environment, and diminishing our view of the stars. DarkSky International has a plan to save the night, but we need your help. The stars are disappearing Join the movement and help save the night DarkSky is a global community working together to save the night. Sign-up today for DarkSky e-news updates to learn more. DarkSky International is a U.S.-based 501(c)(3) nonprofit that supports a global community and movement dedicated to preserving and protecting the natural nighttime environment. DarkSky International 5049 East Broadway Blvd #105 Tucson AZ 85711 USA www.DarkSky.org +1-520-293-3198 Light pollution is reversible! Unlike other forms of pollution, light pollution is a problem with solutions that are easy to implement. These solutions deliver immediate and lasting results. S U C C E S S S T O R Y In 2018, the City of Tucson, Arizona, U.S.A. (population 500,000) upgraded its streetlights. By doing so, it saved $2.2 million per year in energy costs and reduced light pollution by 7%. W E ’R E M A K I N G A N I M P A C T 1,000+ More than 1,000 DarkSky Approved lighting fixtures are available on the market. 2,000+ DarkSky supports more than 2,000 volunteer Advocates in 49 countries. 70+ DarkSky supports more than 70 chapters in 24 countries. 200+ More than 200 International Dark Sky Places have been certified, protecting over 160,000 sq km of dark places around the globe. Photo credit: Bin Chen Light pollution... What is light pollution? Light pollution is the human-made alteration of outdoor light levels from those occurring naturally. When we over-light, fail to use timers and sensors, or use the wrong color of light, we negatively affect many parts of our world. Destroys critical wildlife habitat Plants and animals depend on Earth’s daily light and dark cycle to govern life-sustaining behaviors. Research shows that artificial light at night has adverse and even deadly effects on many species. Wastes energy and money Most outdoor lighting is wasted. This energy waste increases greenhouse gas emissions contributing to climate change and wastes billions of dollars each year. Harms human health Studies indicate that artificial light at night negatively affects human health by increasing our risks for obesity, sleep disorders, depression, diabetes, breast cancer, and more. Decreases safety and security There is no clear scientific evidence that increased outdoor lighting deters crime. In fact, glare from unshielded streetlights can decrease personal safety, contributing to both crime and accidents. Robs us of our night sky heritage Our ancestors experienced a night sky that inspired science, religion, philosophy, art, and literature. Now, millions of children across the globe will never know the wonder of seeing the Milky Way. Inhibits scientific research Satellites in low Earth orbit create visible trails in the night sky, inhibiting astronomical research and jeopardizing NASA’s early warning system for asteroid collisions. What can I do? DarkSky’s Five Principles for Responsible Outdoor Lighting can help you make smart choices to reduce light pollution. Do your lights protect the night? All light should have a clear purpose. Use lights only when and where they are needed. Shield and aim your light so it only falls downward and where it is useful. Lights should be no brighter than necessary to save money and reduce glare. Lights should only be on when needed. Use timers and motions sensors. Warm-colored light causes less skyglow. Use amber-toned lights whenever possible. Is it useful? Is it targeted? Is it low-level? Is it controlled? Is it warm-colored? Visit darksky.org to learn more about the importance of the night and what you can do to reduce light pollution around your home and community. Learn more Learn more about light pollution 1441 Edgewood Dr Palo Alto, CA 94301 April 26, 2025 Kelly Cha Senior Planner Planning and Development Services 250 Hamilton Avenue, Fifth Floor Palo Alto, CA 94301 RE: Outdoor Lighting Update (“Dark Sky”) Dear Ms. Cha: I shared in my prior letters to you and city staff (“Staff”), the Planning & Transportation Committee (“PTC”), and the City Council for the City of Palo Alto (“City Council”) my opposition to the proposed lighting ordinance currently under consideration. I watched with great sadness the City Council on April 7, 2025 pass a motion to incorporate even more egregious conditions into the poorly drafted outdoor lighting ordinance, particularly the expansion to cover any existing light after 10 years. As Staff prepares a new draft ordinance responsive to the City Council’s motion, I ask Staff to consider the following:  Deep security concerns. Residents of Edgewood Dr have a valid and deep concern about safety and security given the frequent and repeated crime we and our property face, the growing unhoused population living immediately adjacent in the San Francisquito Creek (“Creek”) combined with the City’s unwillingness or inability to address the growing issue, and our immediate proximity to East Palo and the spillover impact of frequent crime. The most obvious remedy is to exempt houses on this street from the ordinance or significant portions of the ordinance. While I appreciate Staff’s concern with defining a “high crime” neighborhood, it is vital that the City Council’s direction to address those with “special security concerns” provides adequate relief for homeowners abutting the Creek to install and operate sufficient lighting to protect ourselves. I am terrified of the safety issues my wife and young daughter will face returning to a dark house, trying to take out the trash through a dark backyard, as they are forced to navigate an unlit pool, or are unable to see criminals accessing our yard. Through expensive renovations we can mitigate some of the safety issues caused by this poor ordinance, some of the most severe will remain. Fear for our safety and security is heightened when combined with the other ordinances also under consideration – imagine being forced to no longer allowed have adequate outdoor lighting, no longer allowed to maintain a fence separating you from criminals and unhoused population, and then having to cover your windows in dots so you cannot even see the criminals concealed in the darkness with unfettered access to your backyard. These ordinances, individually and collectively, greatly compromise our safety and security. Please understand these fears are very real for us; we have even started to look at buying firearms and obtaining conceal and carry permits just so we can come home at night! - 2 -  Cost to comply exception / legal challenges and taking claim. With the expansion to cover all existing fixtures, the City must add an exception for properties that would incur excess cost to comply. After years of planning and building, I recently completed construction of my brand new home which I previously expected to be our family’s “forever” home. The preliminary estimate to comply with the new draft code as written requires that I destroy approximately $90,000 of lighting (and fan) materials and spend approximately $210,000 in new materials and labor. (This is just for the fixtures and related costs. The systems upgrades described later add further to this loss.) In 10 years, this would represent approximately $350,000 or more of expense (based on forecasted inflation rates). I can only imagine how much worse that will get with most of these fixtures and luminaires manufactured overseas. Imposing such extraordinary costs on homeowners is patently unfair. Would you want to have to work for 1-2 years just to comply with a new ordinance passed by the city? While my costs may be greater than some others, the cost to completely replace exterior lights for homeowners across Palo Alto is likely to be extremely high and grossly underestimated by City Council. Do we really want to pass this cost to so many homeowners? Do we really want to produce this much waste? A hardship exemption for only a temporary period of time, or requiring proof of financial distress, is wholly insufficient to remedy this loss. A cost to comply exemption is needed. Absent such an exception, it is paramount Staff and the City Attorney advise the City Council that passing such an ordinance leaves the city liable for a takings claim. While it is not my preference, please understand that passing an ordinance with a present value cost to me of $210,000 leaves me with no recourse but to challenge of the ordinance’s validity in court and assert a takings claim against the City for the entirety of this loss.  Shielding standard for non-confirming lighting after 10 years. The overwhelming majority of the costs noted above arise from the shielding requirement applied to non-conforming lights after 10 years. One of the primary stated objectives of the ordinance is to reduce light pollution and minimize visual impact to neighbors. If the 10 year restriction is included in the next draft ordinance, I strongly recommend and beg to allow non-shielded lights so long as their lux output (as measured at the property border) satisfies the light trespass requirements (previously 0.5 lux but now proposed to be 0.1 lux). Like many homeowners, this would mean I would not be required to replace every fixture and could instead replace the luminaire and/or use dimming to bring existing fixtures into compliance. While this would not completely solve glare, this would meet the primary objectives of the ordinance with far reduced cost to homeowners. Moreover, this would further benefit the community since many fixtures would then have the “technical capacity” to comply under the 2 year window rather than waiting the full 10 years.  Lighting output measurement lumens vs lux. Most of the restrictions in the proposed ordinance 18.40.250 are written with regard to “lumens” of output. The original draft ordinance applied to new construction or new luminaires. As such, “lumens” was chosen presumably to make it easier for buyers to select luminaires with said rated lumens output (and for Staff to validate those specs during Planning). Now that the code will extend to existing luminaires, it is vital the code also express the limits in lux. It is my understanding that measuring lumen must be performed in a laboratory. I am told it is not practical to measure lumen output of an existing luminaire in the field. The could would therefore set a standard that could not be objectively measured by code enforcement either. Moreover, lumen is often the theoretical maximum which - 3 - is reduced by the quality of the actual luminaire, the power system, distance, and other factors. One important benefit of expressing output in lux is that it will also allow lighting designers to construct systems with dimmed lights. Most lighting systems are better served running well below 100% of maximum output to extend the lifetime of transformers and luminaires, therefore reducing cost and waste. Most importantly, it will fixtures with luminaires that cannot comply by lumen to comply through dimming. For example, I have two outdoor fan with a down light, adjustable color that can be made to work at 2700K or less, but with lumen that is too high. The manufacturer does not make a down light that meets the lumen requirements. The light, however, is dimmable and could remain if a lux threshold were established.  Conflict in 18.40.250(f)(1)(B) with 18.40.250(e)(1). The draft ordinance 18.40.250(f)(1)(B) states that “No more than 420 lumens shall be allowed for permitted non-shielded outdoor lighting.” The drafting suggests the intent of this section is to allow non-shielded low voltage outdoor lights so long as the luminaire is less than or equal to 420 lumens. Section 18.250(f)(1) also states that low density outdoor residential lights are subject both to that constraint and all others. Section 18.40.250(e)(1)(B) states that all lights must be fully shielded unless it is low voltage up-lights with no more than 150 lumen. This presents a conflict that must be resolved. In the context of this ordinance, the 420 lumens output is most appropriate limit.  Exemptions for front porch. The draft ordinance 18.40.250(d) provides a list of exemptions, including for illuminated street numbers. This exemption presumably recognizes the legitimate public safety need for first responders to locate a property in the event of an emergency. I would contend that providing safety lighting at a property’s front door is a similar legitimate public safety need. Lighting at a home’s primary ingress and egress is of importance to guests, first responders, and others. For most properties, it is impractical to install motion sensors on a front porch. Given this ordinance is being applied to an urban center, lighting the front porch should be exempted, at least with regard to curfew.  Outdoor security light output. The outdoor security lighting output proposed in 18.40.250(f)(2)(D) is limited to 1,600 lumens. First, this is grossly inadequate for security light output over large areas. The result would force homeowners to install multiple security lights, which is both expensive and likely to be worse for light pollution (not to mention potentially more false positives). Instead, this section for outdoor security lights should be limited only to lux light trespass only as already provided in 18.40.250(f)(2)(C). Therefore, sub-paragraph (D) should be removed. It is worth nothing this change would greatly aid Edgewood residents with a legitimate safety need.  Outdoor security light programmability. The draft code 18.40.250(f)(2)(A) requires outdoor lights to be “fully programmable.” It is entirely unclear from the code, common knowledge, or from consulting experts as to what “fully programmable” means with respect to an outdoor security light. This statement should be removed. - 4 -  Outdoor kitchen lighting. The draft code 18.40.250(e)(3)(A) requires all outdoor lights to be 2,700K or less. Lighting professionals routinely recommend 3,000K for kitchens for safety. As with others, my brand new construction followed the lighting professionals’ recommendation and installed 3,000K luminaires in down lights at the outdoor kitchen (with all other outdoor lights of 2,700K). To promote safety, and in consideration that these are not decorative lights but instead task lights for preparing food, it would be reasonable to allow 3,000K luminaires in such down lights when they illuminate an outdoor kitchen.  Control light sensor. The draft code 18.40.250(e)(4)(C) requires lighting control systems to have a light sensor. As noted elsewhere, I recently built a new home. The residence includes a whole-house lighting control system from a well-known manufacturer. The professional lighting designers hired for the project all systematically recommended against a light sensor on the roof for the whole house system given their poor sensitivity and likelihood of failure. They instead all universally recommended time-based automation. In fact, the most common light sensor from the manufacturer used was discontinued years ago because they are so infrequently installed in today’s lighting control systems. The draft code already provides for time-based extinguishing of lights. Therefore, the only practical purpose of this provision is with regard to when lights are allowed to turn on. I therefore recommend adding a time-based alternative to a light sensor. Again, as a practical example, it will cost me approximately $25,000 to add a light sensor to the lighting control system (if I am unable to find the discontinued part, otherwise the cost will likely be over $1m to replace the entire lighting system), whereas it is a simple program change to set the lights to not come on until after a specific time of morning. As noted at the start, I strongly oppose the current ordinance requested by the City Council. I am even more concerned about the cumulative impact of these ordinances: lighting update, bird design standard, and stream protection. Taken together, they effectively condemn my new home as unlivable while incurring massive costs. The foregoing analysis offers several areas where this specific proposed lighting code update could be made substantially less burdensome without materially impacting the stated objectives. Sincerely, Tom Fountain 1441 Edgewood Dr Palo Alto, CA 94301 May 4, 2025 Kelly Cha Senior Planner Planning and Development Services 250 Hamilton Avenue, Fifth Floor Palo Alto, CA 94301 RE: Outdoor Lighting Update (“Dark Sky”) Dear Ms. Cha: I am writing as a follow-up to my letter of April 26, 2025 regarding the City of Palo Alto’s (the “City”) proposed lighting update. As shared previously, I strongly oppose the proposed ordinance and was deeply disturbed by the direction of the City Council on April 7, 2025. I spent my weekend attempting to apply the proposed ordinance to each of the outdoor luminaires and lamps on my property. As Staff prepares a new draft ordinance responsive to the City Council’s motion, I ask Staff to consider the following recommendations in addition to those shared previously:  Measuring light output and promoting hex filters. The draft ordinance currently expresses lamp output limits in lumen. As noted in my prior letter, once extended to existing lamps, it is vital to instead measure the foot-candles (or lux) at the property border or express these limits as the maximum measured output in foot-candles at a specific distance. I also noted previously the importance of allowing field measurements to encourage dimming. This would significantly reduce the cost to property owners since existing lamping is often dimmable. With or without either of these improvements to the draft code, please also consider allowing lighting designers to account for hexagonal cell louver filters (sometimes called “honeycomb” filters). Such filters significantly reduce glare and typically reduced effective light output by 20- 25% even though, by definition, the lamp’s lumen output is unchanged. Limiting output to a measured foot-candle value would account for filters without further change. If limits remain only in the lamp’s manufacturer-specified lumen, consider instead limiting output to the product of the lamp’s lumen times the effective light output if filtered. Alternatively, the lumen could be expressed both with and without a filter. For example, the low-voltage lighting might be limited to 150 lumen without a filter and 200 lumen when a hexagonal cell louver filter is installed. As a result, some property owners could install filters in existing luminaires and lamps rather than having to replace the entire luminaire and/or lamp. Taking hex filters into account would reduce the cost to comply with this proposed ordinance while simultaneously reducing glare and better achieving the stated objectives of the ordinance.  Clarify low-voltage shield exception in 18.40.250(e)(1)(B)(i). The draft ordinance section 18.40.250(e)(1)(B)(i) is intended to provide an exception for unshielded low-voltage lighting. The current draft states this exception applies only to “low voltage landscape uplighting” (underlined for emphasis). Limiting this exception to only “uplighting” is confusing and - 2 - unnecessary. Presumably “uplighting” means anything that is not “Fully Shielded” but that is ambiguous from the context. Moreover, lighting designers should be encouraged, not discouraged, from using low voltage downlights even if they fail to fully satisfy the “Fully Shielded” definition. Consider as an example the FX Luminaire LED Wall Light (h ps://www.fxl.com/product/wall-and-step-lights/designer/mo ). Only one faceplate, the one identified as WW, qualifies as “Fully Shielded,” none would be easily identifiable as “uplighting,” yet all should be in the scope intended by the low-voltage shield exception. Striking the word “uplighting” resolves this drafting issue.  Correct fully shielded security lighting in 18.40.250(f)(2)(B). The draft ordinance 18.40.250(f)(2) is intended to allow outdoor security lighting that meets certain standards. Section 18.40.250(f)(2)(B) establishes a height standard. The statement also requires that luminaire be “fully shielded”. Based on the definition of “Fully Shielded” provided in this draft ordinance, effectively no security light could comply. Compliance would require the light be installed such that lamps point straight down. Any projection “forward” of the luminaire would result in the lamp breaking the required plane extending from the bottom of said lamp. The requirement that these lights be “fully shielded” should be removed from this ordinance. If the intent of this phrase is to encourage security lights be aimed in a downward direction, then it should say so rather than reference “fully shielded” which has a specific definition.  Address security perimeter lighting in 18.40.250(f)(2)(C). City Council directed Staff to replace all references to 0.5 foot-candle of spillover with 0.1 foot-candle of spillover. This change, even if applied elsewhere, should not be applied to this section. A limitation of 0.1 foot- candle effectively eliminates the use of security lighting near a fence. Even if aimed down, reflected light off other surfaces will exceed this threshold. It is untenable to have security lighting so limited where it is needed to illuminate an area near a fence.  Correct typo shielding exception in 18.40.250(e)(1)(iii). Section 18.40.250(e)(1)(iii) provides an exemption for string lights and erroneously refers to 18.40.250(f)(5). It should instead refer to 18.40.250(f)(6). Thank you for your continued work to craft an ordinance that does not create such negative impact to city residents. Sincerely, Tom Fountain From:Emily Renzel To:Council, City Subject:Please adopt strongest possible lighting ordinance Date:Monday, November 10, 2025 12:09:10 PM CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links. Dear Mayor and Members of the City Council: Please adopt the recommendations of the Sierra Club and the Santa Clara Valley Bird Alliance for the strongest possible lighting ordinance. So few natural areas are left that we have to make our urban areas as safe and welcoming to birds and wildlife as we can. Lighting can be particularly disruptive to migrating birds, so please consider that as you adopt the lighting ordinance. Thank you. Emily M. Renzel Councilmember 1979-1991 From:Aiden Miao To:Council, City Subject:11/10/25 Agenda Item 8: Please adopt a strong outdoor lighting ordinance Date:Monday, November 10, 2025 12:04:51 PM CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. i Dear Councilmembers, I'm Aiden, a Junior at Palo Alto High School and a member of the Palo Alto Student Climate Coalition (PASCC). I've grown up in Palo Alto my whole life. Please adopt a strong ordinance to protect birds, people, and our night sky. There is something special about seeing the stars that I believe all Palo Alto residents should have the privilege of experiencing. Best, Aiden Miao This message needs your attention This is a personal email address. Mark Safe Report Powered by Mimecast From:Phyllis Brown To:Council, City Subject:11/10/25 Agenda item 8: please adopt a strong outdoor lighting ordinance. Date:Monday, November 10, 2025 9:33:57 AM CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. Mayor Lauing and members of the Council, The "Dark Skies Initiative" on the website of the McDonald Observatory, University of Texas at Austin, lists six negative effects of light pollution: costs, energy consumption, health, safety, the invironment, and loss of nighttime sky. The website also lists four night-sky friendly lighting practices. I urge the Council to adopt "an Ordinance Updating Palo Alto Municipal Code (PAMC) Section 18.40.250 (Lighting) of Chapter 18.40 (General Standards and Exceptions) and Amending Chapters 18.10, 18.12, 18.28, and Section 18.40.230 of Title 18 (Zoning) to Adopt New Outdoor Lighting Regulations." All living beings deserve to live without unnecessary and damaging artificial light pollution. Phyllis Brown From:Kat Snyder To:Council, City Subject:Dark Sky Ordinance Date:Monday, November 10, 2025 9:23:01 AM CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. i Dear Council, Thank you so much for taking up discussion on the Dark Sky Ordinance. Growing up in Palo Alto, I have very fond childhood memories of looking up at the stars and finding the constellations at night from my own backyard. I also have fond memories of going out camping at Sequoia National Park and being able to actually see the Milky Way! I will defer to you on any policy specifics, I just wanted to note that this is an important topic, not just to help the birds but also to create a sense of wonder among children growing up and looking at the stars. Take care, ~Kat Snyder Palo Alto Resident This message needs your attention This is a personal email address. Mark Safe Report Powered by Mimecast From:Kaitlyn Parkins To:Council, City Subject:11/10/25 Agenda Item 8: Support for Adoption of an Ordinance Updating Palo Alto Municipal Code (PAMC) to Adopt New Outdoor Lighting Regulations Date:Monday, November 10, 2025 9:10:56 AM Attachments:ABC Lighting Ordinance Support.pdf CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. i November 7, 2025 Re: 11/10/25 Agenda Item 8: Support for Adoption of an Ordinance Updating Palo Alto Municipal Code (PAMC) to Adopt New Outdoor Lighting Regulations Dear Councilmembers, I am Kaitlyn Parkins, M.S., Coordinator of the Glass Collisions Program for American Bird Conservancy (ABC) and I have studied and advocated for the prevention of bird-window collisions for over ten years. ABC is dedicated to conserving wild birds and their habitats throughout the Americas. On behalf of ABC, we thank the City of Palo Alto for its leadership in updating the Outdoor Lighting (Dark Sky) Ordinance. This effort is an important step toward protecting local ecosystems, migratory birds, and human health from the growing impacts of artificial light at night. We urge Council to adopt the ordinance with several key improvements, which will help the ordinance better achieve its intent in reducing unnecessary light at night while maintaining functionality and safety for people. Amend Section 18.40.250(c)(3) to remove the phrase “If a building permit is required” to apply the ordinance to all new installation, replacement, or modification of outdoor luminaires, Remove all retrofit requirements for existing outdoor lighting and apply standards only to new or replacement fixtures (see Request #1), and Shorten the compliance period for easily adjustable existing lighting fixtures to one year. Excessive and poorly designed lighting is a serious hazard for birds. Light pollution disrupts migration, disorients nocturnal species, and fragments habitat. The Bay Area lies along the Pacific Flyway, where millions of birds depend on dark skies to navigate safely. Beyond birds, artificial light at night affects virtually every group of organisms, including insects, amphibians, mammals, plants, and humans, by disrupting natural rhythms, feeding and breeding behavior, pollination, and sleep cycles. Palo Alto’s leadership can make a real difference in reducing preventable bird mortality and improving ecological and human health across the region. We also want to address concerns that lower color temperatures, reduced brightness, curfews, and This message needs your attention This is their first email to your company. Mark Safe Report November 7, 2025 Re: 11/10/25 Agenda Item 8: Support for Adop�on of an Ordinance Upda�ng Palo Alto Municipal Code (PAMC) to Adopt New Outdoor Ligh�ng Regula�ons Dear Councilmembers, I am Kaitlyn Parkins, M.S., Coordinator of the Glass Collisions Program for American Bird Conservancy (ABC) and I have studied and advocated for the preven�on of bird-window collisions for over ten years. ABC is dedicated to conserving wild birds and their habitats throughout the Americas. On behalf of ABC, we thank the City of Palo Alto for its leadership in upda�ng the Outdoor Ligh�ng (Dark Sky) Ordinance. This eﬀort is an important step toward protec�ng local ecosystems, migratory b irds, and human health from the growing impacts of ar�ﬁcial light at night. We urge Council to adopt the ordinance with several key improvements , which will help the ordinance beter achieve its intent in reducing unnecessary light at night while maintaining func�onality and safety for people. • Amend Sec�on 18.40.250(c)(3) to remove the phrase “If a building permit is required” to apply the ordinance to all new installa�on, replacement, or modiﬁca�on of outdoor luminaires, • Remove all retroﬁt requirements for exis�ng outdoor ligh�ng and apply standards only to new or replacement ﬁxtures (see Request #1), and • Shorten the compliance period for easily adjustable exis�ng ligh�ng ﬁxtures to one year. Excessive and poorly designed ligh�ng is a serious hazard for birds. Light pollu�on disrupts migra�on, disorients nocturnal species, and fragments habitat. The Bay Area lies along the Paciﬁc Flyway, where millions of birds depend on dark skies to navigate safely. Beyond birds, ar�ﬁcial light at night aﬀects virtually every group of organisms, including insects, amphibians, mammals, plants, and humans, by disrup�ng natural rhythms, feeding and breeding behavior, pollina�on, and sleep cycles. Palo Alto’s leadership can make a real diﬀerence in reducing preventable bird mortality and improving ecological and human health across the region. We also want to address concerns that lower color temperatures, reduced brightness, curfews, and mo�on sensors could compromise community safety. Responsible ligh�ng— warm, shielded, and appropriately dimmed—improves visibility by reducing glare and preserving contrast. Mo�on sensors further support safety by providing light only when and where it is needed, drawing aten�on to ac�vity while preserving darkness at other �mes. Communi�es across the country have successfully implemented similar standards. Research and experience demonstrate that safety and environmental stewardship are not mutually exclusive. By adop�ng this ordinance, Palo Alto can take a meaningful step toward protec�ng both people and wildlife. The updated standards will reduce preventable bird mortality, conserve energy, and create a safer, healthier nigh�me environment for residents and the many species that share the landscape. Palo Alto’s leadership on this issue will set an important example for other ci�es working to balance safety, sustainability, and stewardship of the natural world. Sincerely, Kaitlyn L. Parkins, M.S. Glass Collisions Program Coordinator American Bird Conservancy motion sensors could compromise community safety. Responsible lighting— warm, shielded, and appropriately dimmed—improves visibility by reducing glare and preserving contrast. Motion sensors further support safety by providing light only when and where it is needed, drawing attention to activity while preserving darkness at other times. Communities across the country have successfully implemented similar standards. Research and experience demonstrate that safety and environmental stewardship are not mutually exclusive. By adopting this ordinance, Palo Alto can take a meaningful step toward protecting both people and wildlife. The updated standards will reduce preventable bird mortality, conserve energy, and create a safer, healthier nighttime environment for residents and the many species that share the landscape. Palo Alto’s leadership on this issue will set an important example for other cities working to balance safety, sustainability, and stewardship of the natural world. Please find a PDF of our comments attached. Sincerely, Kaitlyn Parkins Glass Collisions Program Coordinator American Bird Conservancy kparkins@abcbirds.org US Mountain Time Zone From:herb To:Council, City; Clerk, City Subject:November 10, 2025 City Council Meeting, Item # 8: Outdoor Lighting Regulations Date:Sunday, November 9, 2025 5:35:38 PM CAUTION: This email originated from outside of the organization. Be cautious of openingattachments and clicking on links. NOVEMBER 10, 2025 CITY COUNCIL MEETING AGENDA ITEM #8: OUTDOOR LIGHTING REGULATIONS Unshielded LED Street Lights appear to be the main cause of lightpollution that I notice in the areas of the city that I walk in when inappears to be daytime instead of night when there is no light fromeither the sun or the moon, but the City's LED Street Lights are notcovered by this proposed Ordinance. Staff first implemented the conversion of High Pressure Sodium streetlights to LED street lights as a pilot project, and then obtained CityCouncil approval to install the LED street lights in phases. (See streetlight-conversion-project-map.pdf. At first it appears that staff did the conversion, but the most recentareas of the City were converted by contract. (See staff report #4116at https://www.cityofpaloalto.org/files/assets/public/v/1/agendas-minutes-reports/reports/city-manager-reports-cmrs/year-archive/2013/final-staff-report-id-4116_led-street-lights-supply-and-installation.pdf.) The Bid Summary Sheet at page 5 of that staff report indicates thatonly 100 house-side shields and 100 cul-de-sac-side shields were to beremoved as part of that contract, which implies that for the most partshields remained, but I haven't had the opportunity to walk at nightthrough the areas of the city covered by the contract. When I walk at night on the 1100 block of Waverley Street betweenLincoln Avenue and Kingsley Avenue, the street lights on one side ofthe street light up the sidewalk on the other side of the street. Tonight Sunday, November 9, there will be a period of time betweenAstronomical Twilight (about 6:30 pm) when there is no light from thesun, and Moonrise (about 9:30 pm) when there is no light from the moon. If you have an opportunity to walk on the 1100 block of Waverley atthat time, check to see if the sky is dark and you can see the stars,and walk on the side of the street opposite the side with the LEDStreet Lights to see if the sidewalk is dark or light. You need to know the Color Temperature of those LED Street Lights thatmight be different for different manufacturers. Thank you for your consideration of these comments. Herb Borock From:Tom Fountain To:Council, City; Lauing, Ed; Cha, Kelly Subject:Proposed Outdoor Lighting Ordinance Date:Sunday, November 9, 2025 12:24:40 PM CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. i Dear Honorable Mayor and Members of the City Council, With respect to the proposed lighting ordinance, I am writing to support the Edgewood Neighborhood Alliance’s position on the following: I support the exemption of homes on the creek-side of Edgewood Drive given their unique circumstances, including encampments in the creek, crime and quality of life issues, and access from East Palo Alto which lacks barriers to creek entry. There is a well-documented threat to health and safety of residents that demands this reasonable exemption. The exemption for Edgewood properties contains an error and should be corrected to the following: “(7) Single family residential sites adjacent to San Francisquito Creek and fronting on Edgewood Drive if the portion of the site subject to a permanent easement in favor of the Santa Clara Valley Water District (or its successor in interest) for flood control purposes is reconfigured after January 1, 2002. These sites shall be subject to the requirements under Section 18.40.250(e)(4)(A).” More generally, I oppose the proposed ordinance. I hereby incorporate by reference my prior objections expressed in writing to the City Council, the Planning & Transportation Commission (PTC), and city staff. This ordinance fails to adequately establish the relationship between the new regulation and the proven benefit. The proposed ordinance imposes an unreasonably high burden on existing residences. In many cases it requires homeowners to replace entire fixtures, not just bulbs. As but one example, the estimated cost to bring my property into compliance is $210,000 between new light fixtures and having to replace custom cuts of stone, siding, and other materials upon which these fixtures are mounted. The environmental waste produced by this poorly considered ordinance more than offsets the stated environmental benefits. There are many problematic issues raised by this proposed ordinance. The City Council is misguided in stating this is “only” a future cost; every Palo Alto homeowner selling their This message needs your attention This is their first mail to some recipients. Mark Safe Report Powered by Mimecast property must now disclose this future cost to potential buyers. The City’s inability (and stated intent not) to enforce this code only serves to further pit neighbors against one another in a community that is already too acrimonious; City Council should use guidelines and incentives rather than criminalize lighting. There are many other similar technical issues with the proposed code that I have raised on multiple occasions, particularly its applicability to already built residences; it is incredibly disheartening that after 6+ months, staff chose not address even a single issue raised. It leads me to conclude this is entirely performatory and not at all about actually improving the lives of Palo Alto residents. I strongly urge City Council take a more measured and practical approach to advancing this environmental goal. First, these changes should only be applied to new residential construction and not retroactively applied to existing residences. If existing properties must be covered, then limits should be expressed in lux rather than lumen so that practical techniques such as dimming can allow existing fixtures to comply. The current proposed ordinance fails to balance property owner cost with the claimed benefits, creates unreasonable expense for homeowners, causes environmental harm from the premature replacement of fixtures and related construction, and fails to apply even practical solutions such as dimming to lighting issues. As a resident of Palo Alto, I beg City Council to send the ordinance back to Staff to better address these issues. Sincerely, Tom Fountain Palo Alto resident From:Marie Evitt To:Council, City Subject:outdoor lighting ordinance Date:Sunday, November 9, 2025 10:58:29 AM CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. i Dear Councilmembers, I urge you to adopt a strong outdoor lighting ordinance to protect birds, people, and our night sky. I am a Mountain View resident and I hope to reduce light pollution throughout the peninsula and Bay Area. Sincerely, Marie Evitt Mountain View This message needs your attention This is their first email to your company. Mark Safe Report Powered by Mimecast From:Kristin Sato To:Cha, Kelly; Council, City; Lauing, Ed Cc:Tom Fountain Subject:Proposed Outdoor Lighting Ordinance, Line Item #8 Date:Saturday, November 8, 2025 8:00:53 PM CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. i Palo Alto City Council, City.Council@CityofPaloAlto.org Ed Lauing, Ed.Lauing@CityofPaloAlto.org Re: Proposed Outdoor Lighting Ordinance Dear Honorable Mayor and Members of the City Council, With respect to the proposed lighting ordinance, I am writing to support the Edgewood Neighborhood Alliance's position on the following: I support the exemption of homes on the creek-side of Edgewood Drive given our unique circumstances, including encampments in the creek, crime and proximity to East Palo Alto, which have no barriers to enter the creek. The exemption for Edgewood properties contains an error and should be corrected to the following: “(7) Single family residential sites adjacent to San Francisquito Creek and fronting on Edgewood Drive if the portion of the site subject to a permanent easement in favor of the Santa Clara Valley Water District (or its successor in interest) for flood control purposes is reconfigured after January 1, 2002. These sites shall be subject to the requirements under Section 18.40.250(e)(4)(A).” It should be noted though that I generally oppose the proposed ordinance as previously addressed in prior objections to the City Council, the Planning & Transportation Commission (PTC), and city staff. This ordinance fails to adequately establish the relationship between the new regulation and the proven benefit. The proposed ordinance imposes an unreasonably high burden on existing residences -- I moved into my new build house 2 years ago and will now have to spend an inordinate amount of money to bring my residence into compliance. This This message needs your attention This is a personal email address. This is their first mail to some recipients. Mark Safe Report environmental benefits. Further, there are many problematic issues raised by this proposed ordinance. The City Council is misguided in stating this is "only" a future cost; any homeowner selling their property will now need to disclose this future cost to potential buyers. The Edgewood Properties are already being targeted by real estate brokers recommending that we sell quickly because the City's proposed changes will more likely decrease our home values. The City's inability (and stated intent) to not enforce this code only serves to pit neighbors against one another in a place that is already so acrimonious; City Council should use guidelines and incentives rather than criminalize lighting. There are many other similar small issues with this proposed code; it is incredibly disheartening that after 6+ months, staff did not address even a single issue raised. It appears that this is entirely performatory and not at all about actually improving the lives of Palo Alto residents. I strongly urge the City Council to take a more measured and practical approach to advancing this environmental goal. First, these changes should only be applied to new construction and not retroactively applied to existing residences. If existing properties must be covered, then limits should be expressed in lux rather than lumen so that practical techniques such as dimming can allow existing fixtures to comply. The current proposed ordinance fails to balance property owner costs with the so- called proposed benefits, creates unreasonable expense for homeowners, causes environmental harm from the premature replacement of lights and related construction, and fails to apply even practical solutions such as dimming to these issues. Seriously, where is the environmental impact studies that would show the cost benefit to impose such onerous rules on whole City? As a resident of Palo Alto, I ask the City Council to send the ordinance back to Staff to be rewritten. Thank you. Kristin Sato From:Andrea Eckstein Gara To:Council, City Cc:Hilary Glann Subject:Support for Stronger Dark Sky Ordinance from 350 SV Palo Alto Date:Saturday, November 8, 2025 5:54:47 PM CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. i Dear Councilmembers, As advocates for the environment, our group enthusiastically supports the more robust dark sky ordinance under consideration. Motion sensors and controlled, time-activated lights will keep us safe, as well as supporting the nocturnal creatures in our community. Dark skies are an important part of their ecosystem, and should be protected in the same way that we protect other natural habitats, such as Bay Lands and our canopy. Nearly half of the species on earth are nocturnal. Dark skies cue important behaviors and help them to navigate, nest, mate, forage, and hide from predators. Insects are particularly vulnerable to light pollution. This is just one modern stressor, and scientists have reported that we are experiencing an insect apocalypse with 75% of the insect biomass disappearing in just 30 years. As insects are a critical component of many food webs, we know that there will be ripple effects for birds, fish, mammals and humans. About 75% of our crop varieties depend on insect pollination. Reduced yields lead to cascade events that have real human health impacts. Finally, a dark sky can be a form of natural beauty that is available to anyone, even those without easy access to gardens and parks. We know that exposure to natural beauty and awe has many physical and psychological benefits, lowering anxiety, improving concentration, and reducing inflammation and heart rate. Thank you for continuing to focus on this important topic, and please take the steps needed to make this an ordinance that truly gives us back our night sky. 350 SV Palo Alto This message needs your attention This is a personal email address. This is their first mail to some recipients. Mark Safe Report Andrea Eckstein Gara, Co-chair Hilary Glann, Co-chair From:Bruce England To:Council, City Cc:Bruce England Subject:Comment on agenda item 8 at 11/10 City Council meeting Date:Saturday, November 8, 2025 2:58:03 PM CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. i Hello council members: I would like to voice my support for an outdoor lighting ordinance you will consider at your meeting. Although I'm a Mountain View resident, our own city is working on this as well, and the issue is regional in many respects. We truly need these update rules throughout the South Bay Area, and beyond for that matter. Also, please consider incorporating suggestions from the Bird Alliance and the Sierra Club in the ordinance. During public comments on this, I request that you cede my time to Shani Kleinhaus. Thanks for your attention, Bruce England 328 Whisman Station Drive Mountain View, CA 94043 This message needs your attention This is a personal email address. This is their first mail to some recipients. Mark Safe Report From:Cathy Brown To:Council, City Subject:11/10/25 Agenda Item 8: Please adopt a strong outdoor lighting ordinance Date:Saturday, November 8, 2025 11:11:34 AM CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. i To whom it may concern, Please consider adopting a strong lighting ordinance that helps reduce the amount of light pollution that is created in Palo Alto every night. I have lived here for most of my sixty years and remember being able to see the stars and moon on evening walks. Rarely does that occur now. There are SO many lights everywhere, from solar powered ones that stay on all night, to extremely bright flood lights triggered by someone passing by a home, to bright car and street lights. Lighting helps for safety but we must do it with more care. We are affecting the flights of birds and insects with unknown ripples throughout our ecosystem. Migratory patterns are shifted. As well, every evening I must close doors within my home to block light from my neighbors' myriad of lights which shine all night to have semi-darkness within my bedroom. We have lost the dark of night. Please consider adopting resolutions that will help restore this. Thank you, Cathy Brown Boyce Avenue, Palo Alto This message needs your attention This is a personal email address. This is their first email to your company. Mark Safe Report From:Winter Dellenbach To:Council, City Subject:Needed - The locals need Dark Skies Date:Saturday, November 8, 2025 11:04:58 AM Dear Council Members - It is time our City, often a policy and issue leader, now joined other large and small cities in our state, country and abroad in adjusting needed lightening to a responsible, reasonable level. You are on a Council that pays attention to local residents. It is on their behalf, as seen below, that I write this email (furry feet, nails, hooves and talons prevent them doing so themselves). For the migrating birds, the fish and wildlife along our creeks, for the owls and hawks hunting in our parks and open space that keep vermin in check. And for our own species to see the night sky and to reap the many benefits darker skies foster. An egregious example of over the top lighting is in Bol Park where a very big light is bolted high up in an old Oak tree shining on the path along Matadero Creek, shining way beyond the path onto big grassy areas. There is no need for this. Path lighting needs to be changed so that is low, pointing down on the path and only as needed. Science supports darker skies. Palo Alto should too. Winter Dellenbach From:Paul Lynam To:Council, City Subject:11/10/25 Agenda Item 8: Please adopt a strong outdoor lighting ordinance Date:Saturday, November 8, 2025 2:44:51 AM Attachments:ATTN_Palo_Alto_Couuncil--PLynam_2025-11-08.pdf CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. i Honorable Mayor and City Council, Please find attached a pdf file comprising written public comment regarding "Adoption of an Ordinance Updating Palo Alto Municipal Code [...] for Protection of the Environment", scheduled to come before the Council on 10 November 2025. The University of California Observatories/Lick Observatory (UCO/Lick) endorses the proposed Palo Alto Outdoor Lighting (Dark Sky) ordinance. Furthermore, the Council is encouraged to incorporate the recommendations compiled by expert environmental advocacy groups such as the SCV Bird Alliance. Since light pollution/(A)LAN is a regional trespass, it is best addressed by regional coordination. The proposed ordinance demands ‘increasing efforts to raise awareness’. It is recommended that some of these efforts be directed towards coordinating with neighbouring local authorities with a view to ultimately developing a regional strategy to reduce the light pollution (A)LAN phenomenon. Thank you for your attention and service to the community. Yours faithfully, Dr Paul D. Lynam FRAS Astronomer UCO/Lick Observatory This message needs your attention This is their first email to your company. Mark Safe Report University of California Observatories/Lick Observatory 7281, Mount Hamilton Road, MOUNT HAMILTON, CA 95140 8 November 2025 Honorable Mayor and City Council, Item 8. Adoption of an Ordinance Updating Palo Alto Municipal Code (PAMC) Section 18.40.250 (Lighting) of Chapter 18.40 (General Standards and Exceptions) and Amending Chapters 18.10, 18.12, 18.28, and Section 18.40.230 of Title 18 (Zoning) to Adopt New Outdoor Lighting Regulations; CEQA Status — Exempt pursuant to CEQA Guidelines Section 15308 (Actions for Protection of the Environment) This communication comprises written public comment regarding the above-titled matter scheduled to come before the Council on 10 November 2025. The University of California Observatories/Lick Observtory (UCO/Lick) endorses the proposed Palo Alto Outdoor Lighting (Dark Sky) ordinance for the following reasons: •Public opinion: Experience shows that invariably, the majority public opinion is in favour of measures to control light pollution1 . The needs of astronomical observatories are in accord and well-aligned with Council direction from 7 April 2025, and sentiment expressed by environmental advocates and many public participants in the process. •Astronomy, Environment, Economy: Dark Skies benefit multiple aspects of the environment and economy (including, but not limited to, noturnal nature-based pursuits such as stargazing and astronomical research as well as agricultural pest control). •Public Health: Reduction in harms of (A)LAN to human health, circadian disruption, etc. This correspondent has been an advocate for dark skies for 40+ years, informing local and regional authority lighting policies in Europe and North America. The writer holds a degree in astronomy with applied physics, masters in physics, doctorate in astrophysics and has worked at academic research insti- tutes and/or observatories in the UK, Germany, Chile and the US for 30+ years, joining the University of California Observatories/Lick Observatory (UCO/Lick) — the world’s first high altitude astronomical observatory — in 2011. Lick Observatory hosts over 10 telescopes, plus multiple cutting-edge research and technology development instruments, serving hundreds of faculty (including Nobel laureates) and students of the University of California system, in addition to 35,000 visitors annually. Named in classic literature2 and during the Apollo program3 , Lick Observatory leads the world, setting standards on astronomical matters and responsible lighting. 1 Also referred to in academic literature as Anthropogenic Light At Night (ALAN) or simply Light At Night (LAN) 2 H. G. Wells (1897)The War of the Worlds. 3 NASA Apollo 11 (20 July 1969) CAPCOM to Tranquility Base: ‘The Lick Observatory in California reports a return on the laser experiment’. A fundamental problem pervading California is that the night sky is not considered an environmental phenomenon under CEQA4 ’. This, despite the United Nations declaration: An unpolluted night sky that allows the enjoyment and contemplation of the firmament should be considered an inalienable right of humankind equivalent to all other environmental, social, and cultural rights. By excluding the night sky from its description of ‘the environment’, CEQA is deficient. Hence, it becomes the responsibility of California’s local authorities to safeguard the protection of dark skies and public health. The nature, physics, regional trespass and harms of light pollution/(A)LAN have been understood for decades. The scientific concencus (based on multitudinous, multi-disciplinary, independent, peer- reviewed studies) is indisputable: (A)LAN harms the mission of astronomical observatories; (A)LAN causes changes in the environment that have adverse direct or indirect effects on fauna and flora (e.g. bats, insects, trees) altering our sense of place; (A)LAN is a hazard to human health and probable carcinogen. Blue light (primarily from LEDs5 ) is toxic for all life. Harm to Dark Skies & Astronomical Pursuits The prevalence of light pollution/(A)LAN across the industrialized world is accelerating at a rate out- pacing population growth. Over the past 25 years, growth rates of between 49% and 270% have been measured. For rapidly developing conurbations in the industrialized world (e.g. San Francisco Bay Area) this figure could be as high as 400%. Some estimates suggest growth rates of 7% to 10% annually (Kyba et al. 2023). Light pollution trespasses regionally: Metropolitan light impacts astronomical sites up to 200–300 km away (Duriscoe et al. 2018). Regardless of the technology or originating fixture,any and all light sources which interact with the atmosphere contribute an additive effect to scattered light, elevating the intensity of the diffuse sky background. Every additional light source elevates the problem. Additional scattered light does not simply ‘blend in’ to the pre-existing level of diffuse sky background light. Blue light — particularly (since circa 2013) blue-rich LEDs — contributes disproportionately to light pollution. LEDs combine emission from peaks of intensity across many colors — particularly blue — thus contaminating the entire visible spectrum, whereas incandescent or discharge (e.g. sodium) lighting consists of isolated spectral peaks, with adjacent spectral regions free from contamination. In particular, with few exceptions, practical electric lights prior to LEDs were wholly absent of a blue component. In contrast,LEDs produce a preponderance of blue light. In large part, sky-glow is a consequence of the physics of ever-present aerosols (e.g. water vapor, particles, etc.) which redirect, or scatter light — not exclusively direct illumination. Scattering is responsible for twilights, renders clear daytime skies as blue and cloudy skies as gray. One of the dominant scattering processes,Rayleigh scattering, has not simply an additive or multiplicative dependence, but a fourth-order power law dependence, such that bluer (shorter) wavelengths are much more strongly scattered than redder (longer) wavelengths . 4 CEQA: The California Environmental Quality Act. 5 LEDs: Light Emitting Diodes 2 DarkSky Recommendations The proposed ordinance incorporates best practice guidelines recommended by DarkSky International 6 to minimize damage to dark skies,and address the pleas of researchers to reduce, curb, mitigate or reverse the proliferation of light pollution/(A)LAN: To maintain our ability to carry out top-grade astronomical research, it is nec- essary that the [A]LAN affecting observatories is reduced as soon as possi- ble . . . [this] might be the last call for a serious, collective, unambiguous, no- compromise action to lower light pollution now. — Falchi et al. (2023) Harm to Public Health from Pervasive Light Pollution: ‘Edison’s Cancer Epidemic’. Light pollution from artificial light is harmful to human health — considered by some ‘the biggest public health crisis going on right now7 ’. Every major disease is associated to some extent with short sleep/long light. Sleep disorders are now arguably the most prevalent health concern in the industrialized world (Bogard 2013, Winter 2017).The consensus that has emerged from over 10,000 peer- reviewed scientific articles published by over 30,000 scientists cements the conclusion that light at night is carcinogenic, as well as causing a host of other medical problems. Mammals are highly sensitive to light at night, which has the power to dramatically, negatively affect circadian rhythms. Circadian rhythms control aspects of physiology, behavior, metabolism, body temperature, blood pressure and pineal hormone (e.g. melatonin) secretion. It is the shorter wavelengths of light (i.e. blue) that most affect melatonin production. LEDs — with their preponderance of blue emission — are of most concern. Beginning in 1970s, multitudinous studies have identified links between circadian disruption to behav- ioral changes,sleep disorders, (e.g. Wang et al. 2022),mental disorders, (mood and anxiety disorders e.g. Paksarian et al. 2020),diabetes, (e.g. Zheng et al. 2023),depression,obesity,coro- nary heart disease, (e.g. Muenzel et al. 2020, and references therein), Mild Cognitive Impairment, MCI (a transitional phase between normal aging and dementia e.g. Chen et al. 2022),dementia and Cerebrovascular disease (including stroke and other conditions affecting blood flow to the brain e.g. Wu et al., 2024). Circadian disruption, induced by light pollution, is harmful — considered a probable human carcino- gen by WHO8 (Stevens et al. 2011, Bogard 2013). The US National Institutes of Health (NIH) concurs: review panels at the WHO and US NIH have confirmed the carcinogenic risk of electric light. The American Medical Association (AMA) and groups (e.g. The American Heart Association, heart.org/stroke.org;breatscancer.org; The Sleep Foundation) advocate for light pollution control efforts for public safety. Hundreds of scientific studies have shown the association between electric light exposure and cancer, and the biological mechanisms by which it occurs. Electric light has been called ‘the tobacco of breast and prostate cancer’. These two cancers — along with 6 DarkSky International (formerly, the International Dark-Sky Association). 7 Clip: Prof. R. Fosbery: Interactions between light & life (21 October 2022) [02:16–02:24]. 8 The World Health Organization. 3 cancers of the lung, colon and rectum have multiple, well-established causal pathways between those cancers and light pollution. Modern texts describe the prevalence of light at night as ‘Edison’s Cancer Epidemic’ (Moore-Ede 2024). Over the past decade, ‘mitigation’ has gradually been expunged from the lexicon of students of (A)LAN and dark-sky advocates. Multi-disciplinary, independent, peer-reviewed scientific studies plead: We advise people, especially those living in urban areas, to consider reducing exposure [to outdoor artificial light] to protect themselves. — Jianbing Wang, Ph.D (25 March 2024)9 Harm to Public Health from LEDs: ‘The New Asbestos’ We are now realizing that ‘blue light is toxic for all life10 ’. Light at night originating from LEDs directly damages cellular mitochondria via ‘the same process produced by Chernobyl radiation [. . . ] a slow death11 ’. Public health experts refer to the effect of growing light pollution as ‘21st century scurvy’. LEDs are described as ‘the New Asbestos12 ’. We may regret [introducing LED and fluorescent light tubes] due to to health hazards as well as economic and social costs associated with it, and, therefore, it should be considered unsustainable. — Haim & Portnov (2013) Conclusion The message is clear, the astronomical community, dark-sky advocates, environmentalists, public health researchers are pleading for: Serious, collective, unambiguous, no-compromise action to lower light pollution now. — Falchi et al. (2023) Curb the surging light pollution at night. — Chen et al. (2022) Reduce artificial light at night. —Al Nagger & Anil (2016) 9 American Heart Association/heart.org/stroke.org 10 Clip: Prof. R. Fosbery: Concerns on the impact of life from blue light LEDs (12 May 2022) [05:52–06:03]. 11 Clip: Prof. R. Fosbery: Interactions between light & life (21 October 2022) [01:02:05–01:02:16]. 12 Clip: Prof. R. Fosbery: Interactions between light & life (21 October 2022) [01:04:40–01:04:52]. 4 Regulations on nighttime advertising [. . . ] and switching off. — Haim & Portnov (2013) The City of Palo Alto is not alone in considering and/or adopting new outdoor lighting regulations: In nearby communities such as West Marin and Santa Rosa, citizens have been proactive in demanding DarkSky-compliant lighting ordinances. Similar efforts are gaining traction at State level (witness the progression of legislation to reduce light pollution13 ). The time is coming when light pollution will be as strictly regulated as noise or air pollution (Ecklof 2023). Again, the University of California Observatories/Lick Observatory (UCO/Lick) endorses the proposed Palo Alto Outdoor Lighting (Dark Sky) ordinance. Furthermore, the Council is encouraged to incor- porate the recommendations compiled by expert environmental advocacy groups such as the SCV Bird Alliance. Since light pollution/(A)LAN is a regional trespass, it is best addressed by regional coordination. The proposed ordinance demands ‘increasing efforts to raise awareness’. It is recommended that some of these efforts be directed towords coordinating with neighbouring local authorities with a view to ultimately developing a regional strategy to reduce the light pollution (A)LAN phenomenon. Thank you for your attention and service to the community. Yours faithfully, Dr Paul D. Lynam FRAS Astronomer UCO/Lick Observatory 13 Legislation to reduce light pollution progresses to Senate Committee on Appropriations (4 August 2023). 5 References Al Nagger, A., Anil, S. (2016) Artificial Light at Night and cancer: Global Study Asian Pacific Journal of Cancer Prevention, 17 (10), 4661. Bogard, P. (2013) The End of Night: Searching for natural darkness in the age of artificial light Back Bay Books / Little, Brown and Company ISBN 978-0-316-18290-4 (hc) / 978-0-316-18291-1 (pb). Bauby, J-D. (1997) The Diving Bell and the Butterfly Vintage ISBN 9780375701214. Chen, Y., Tan, J., Liu, Y., Dong, G., D., Yang, B. Li, N., Wang, L., Chen, G., Li, S., Guo, Y. (2022) Long-term exposure to light at night and mild cognitive impairment; A nationwide study in Chinese veterans Science of the Total Environment, 847, 157441. Duriscoe, D., Anderson, S., Luginbuhl, C., Baugh, K. (2018) A simplified model of all-sky artificial sky glow derived from VIIRS Day/Night band data Journal of Quantitative Spectroscopy and Radiative Transfer, 214, 133. Eklof, J (2023) The Darkness Manifesto: On Light Pollution, Night Ecology and the Ancient Rhythms that Sustain Life Scribner ISBN-13 978-1668000892. Falchi, F., Ramos, F., Bara, S., Sanhueza, P., Arancibia, M., Damke, G., Cinzano, P. (2023) Light pollution indicators for all the major astronomical observatories Monthly Notices of the Royal Astronomical Society 519, 26. Garstang, R. (1989a) Night-sky brightness at observatories and sites Publications of the Astronomical Society of the Pacific, 101, 306. Garstang, R. (1989b) The status and prospects for ground-based observatory sites Annual Reviews of Astronomy and Astrophysics, 27, 19. Gaston, K. J., Sanchez de Miguel, A (2022) Environmental Impacts of Artificial Light at Night Annual Review of Environment and Resources, 47, 373. 6 Green, R. F., Luginbuhl, C. B., Wainscoat, R. J. Duriscoe, D. (2022) The growing threat of light pollution to ground-based observatories The Astronomy and Astrophysics Review, 30, 1. Haim, A., Portnov, B. (2013) Light pollution as a New Risk Factor for Human Breast and Prostate Cancers Springer Dordtrecht ISBN 978-94-007-6219; Published 12 June 2013. IARC (2020) Night Shift Work IARC Monogr. Identif Carcino Hazards Hum, 124: 1–371. https://www.iarc.who.int/news-events/iarc- monographs-volume-124-night-shift-work/ Kyba, C., Altintas, Y., Walker, C., Newhouse, M. (2023) Citizen scientists report global rapid reductions in the visibility of stars from 2011 to 2022 Science, 379, 265. Miller, S., Cajochen, C., Green, A., Hanifin, J., Huss, A., Karipidis, K., Loughran, S., Oftedal, G., O’Hagan, J., Sliney, D., Croft, R., van Rongen, E., Cridland, N., d’Inzeo, G., Hirata, A, Marino, C., R¨o¨osli, M., Watanbe, S., and International Commission on Nin-Ionizing Radiation Protection (ICNIRP) (2024) INCNIRP statement on short wavelength light exposure from indoor artificial sources and human health Health Physics 126(4), 241–248. Moore-Ede, M. (2024) The Light Doctor: Using light to boost health, improve sleep and live longer Circadian Books ISBN 978-8-9906869-0-8 (pb). M¨unzel, T. Hahad, O., Daiber, A. (2021) The dark side of nocturnal light pollution. Outdoor light at night increases risk of coronary heart disease European Heart Journal 2021 Feb 21; 42(8), 831–834 https://www.ncbi.nlm.nih.gov/pmc/articles/PMC7897459/ Paksarian, D., Rudolph, K., Stapp, E. (2020) Association of Outdoor Artificial Light at Night With Mental Disorders and Sleep Patterns Among US Adolescents JAMA Psychiatry 2020, 77(12), 1266–1275. Stevens, R., Hansen, J., Costa, G. et al. (2011) Considerations of Circadian Impact for Defining ‘Shift Work’ in Cancer Studies: IARC Working Group Report Occupational Environmental Medicine 68, 154. https://pubmed.ncbi.nlm.nih.gov/20962033/ 7 Winter, C. (2017) The Sleep Solution: Why Your Sleep is Broken and How to Fix it Berkley ISBN-13 978-0399583605. Wang, L., Gong, Y., Fang, Q. et al. (2022) Association Between Exposure to Outdoor Artificial Light at Night and Sleep Disorders Among Children in China JAMA Netw Open. 2022 May 2;5(5):e2213247 Wu, Y., Shen, P., Yang, Z., et al. (2024) Outdoor Light at Night, Air Pollution, and Risk of Cerebrovascular Disease: A Cohort Study in China Stroke (American Heart Association Journals), Vol 55, No 4 (25 March 2024) Zheng, R., Xin, Z., Li, M., et al. (2023) Outdoor light at night in relation to glucose homeostatis and diabetes in Chinese adults: a national and cross-sectional study of 98,658 participants from 162 study sites Diabetologia, 66, 336. 8 From:Orly Schube To:Council, City Subject:Support a Strong Dark Skies Ordinance to Support Our City Date:Friday, November 7, 2025 5:17:57 PM CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. i Dear City Council members, My name is Orly Schube, I'm a junior at Paly and part of the Palo Alto Student Climate Coalition. I'm writing to express my strong support for Palo Alto's Dark Skies Ordinance. This policy is an opportunity for our city to take meaningful action that benefits people, wildlife, and the environment. Light pollution has far-reaching effects on both ecosystems and human health. Migrating birds rely on natural light cues from the moon and stars, but excessive artificial light disorients them, leading to collisions with illuminated buildings. Insects, which are critical to healthy food webs, are also fatally attracted to bright, unshielded lighting. By implementing this ordinance, Palo Alto can help reduce bird collisions and insect mortality, restoring balance to local ecosystems along the Pacific Flyway. Light pollution affects people, too. Studies show that artificial light at night disrupts sleep, circadian rhythms, and hormone balance, and has been linked to insomnia and other health risks. Over-lighting and glare can even make streets less safe by reducing contrast and impairing night vision. Adopting this ordinance would make Palo Alto a leader in sustainability and environmental stewardship, protecting our skies, wildlife, and our community's well-being. Thank you for your leadership and for considering this important step toward a healthier, more sustainable future for all of us. Sincerely, Orly Schube Palo Alto High School Palo Alto Student Climate Coalition This message needs your attention This is a personal email address. This is their first email to your company. Mark Safe Report From:Dashiell Leeds To:Council, City; Burt, Patrick; Lauing, Ed; Lu, George; Lythcott-Haims, Julie; Reckdahl, Keith; Stone, Greer; Veenker, Vicki; Cha, Kelly; Clerk, City Cc:James Eggers; Mike Ferreira; Gita Dev; Lait, Jonathan; Armer, Jennifer; Frick, Coleman Subject:SCLP Response to Letter From Stanford Re Nov 10 Dark Sky Ordinance Date:Friday, November 7, 2025 4:38:55 PM Attachments:SCLP Response to Stanford re Nov 10 Dark Sky Ordinance.pdf CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. Dear Mayor Lauing and Palo Alto City Councilmembers, In reviewing the letter sent by Stanford University to the City, the Sierra Club Loma Prieta Chapter has some responses that are relevant to consider as Council deliberates on topics raised by this ordinance. Please read the attached letter for more details. Sincerely, Dashiell Leeds Conservation Coordinator Sierra Club Loma Prieta Chapter SAN MATEO, SANTA CLARA & SAN BENITO COUNTIES November 7, 2025 Palo Alto City Council 250 Hamilton Ave Pave ALto, CA 94301 Responses to Comments Received by the City from Stanford Regarding the Draft Dark Sky Ordinance Dear Mayor Lauing and Palo Alto City Councilmembers, In reviewing the letter sent by Stanford University to the City, the Sierra Club Loma Prieta Chapter has some responses that are relevant to consider as Council deliberates on topics raised by this ordinance. 1. Safety concerns regarding motion sensor outdoor lighting are already addressed by the ordinance The letter from Stanford states the following. “Motion-activated lighting does not provide a sense of safety or security, especially in a complex where tenants do not have fixed closing hours. Maintenance, janitorial, and security staff are often on-site after midnight, and researchers and engineers regularly work late as deadlines approach.” We believe that the concerns raised in this letter would already be addressed by the lighting curfew section of this ordinance, which reads as follows. “(4) Lighting Control. (A) Lighting Curfew. Unlike other provisions in this section, the Lighting Curfew shall apply to all outdoor luminaires for new and existing buildings and structures, unless otherwise approved. All outdoor lighting shall be fully extinguished or be motion sensor operated by 12:00 a.m., two hours after the close of business, or when people are no longer present in exterior areas, whichever is later.” sierraclub.org/loma-prieta ~ 3921 East Bayshore Road, Suite 204, Palo Alto, CA 94303 The underlined wording of this curfew language is extremely flexible, and allows for consistent lighting in situations where people are still present in exterior areas, even after midnight. In areas in Stanford where people are regularly present after midnight, as claimed in the letter, those areas would be allowed to remain consistently lit, according to the curfew language of the ordinance. The ordinance as-written would not require Stanford to use motion-sensor lighting at times when people are usually or regularly present in certain outdoor areas. 2. The lighting levels established by the ordinance offer sufficient lighting for public safety, and avoid the hazards of glare caused by overly bright and ‘cool’ lighting. The letter from Stanford makes the following claim, without citing any scientific studies or specific evidence. “Requiring changes such as adding motion sensors, shrouds, or altering fixtures and bulbs would lead to poor and unsafe lighting conditions.“ However, DarkSky International’s 2025 State of the Science Report1, which is based on an analysis of more than 500 scientific studies regarding artificial light at night, makes the following conclusions regarding over-lighting and its negative effects on public safety. “Glare from bright artificial light sources is a particular concern for nighttime safety. It results from intense light rays entering the eye directly from a source. Some of that light scatters inside the observer ’s eye, reducing the contrast between foreground and background. This effect makes it difficult to see objects as distinct from what surrounds them. Glare reduces the visibility of objects at night for motorists, pedestrians and bicyclists. Although some older observers report stronger sensations of glare from certain sources, it seems to affect people of all ages2. Some modern lighting sources like LED can make glare worse by emitting considerable light at very shallow downward angles3 and also by using non-uniform light sources with insufficient optical diffusion4. The perception of glare seems to vary with the wavelength of light involved. In general, short-wavelength (‘cool’) light causes stronger glare than long-wavelength (‘warm’) light5.” 5 Bullough, J. Spectral sensitivity for extrafoveal discomfort glare. Journal of Modern Optics, 56(13):1518–1522, jul 2009. doi: 10.1080/09500340903045710 4 Yang, Y., Luo, M.R. and Ma, S. Assessing glare. part 2: Modifying unified glare rating for uniform and non-uniform LED luminaires. Lighting Research & Technology, 49(6):727– 742, apr 2016. doi: 10.1177/1477153516642622 3 Kyba, C.C.M., Hänel, A. and Hölker, F. Redefining efficiency for outdoor lighting. Energy Environ. Sci., 7(6):1806–1809, 2014. doi: 10.1039/c4ee00566j. 2 Davoudian, N., Raynham, P. and Barrett, E. Disability glare: A study in simulated road lighting conditions. Lighting Research & Technology, 46(6):695–705, nov 2013. doi: 10. 1177/1477153513510168. 1 https://darksky.org/app/uploads/2025/06/ALAN-State-of-the-Science-2025-EN-2.pdf sierraclub.org/loma-prieta ~ 3921 East Bayshore Road, Suite 204, Palo Alto, CA 94303 The current ordinance, by requiring lights to be fully shielded, prevents the direct light scattering inside the observer's eye that would lead to difficulty seeing objects around them. By avoiding short-wavelength ‘cool’ light, the ordinance avoids the sources of stronger glare that would also reduce nighttime visibility. By ensuring that lighting is not unnecessarily bright at night, the ordinance allows for pedestrians to clearly view lit areas while maintaining situational awareness of their nighttime surroundings. Regarding motion-sensors, we have already established previously in this letter that the existing curfew language is flexible to allow for consistent lighting in outdoor areas where people regularly present after midnight. The ordinance, as written, adheres to the science regarding light pollution and public safety. We are concerned that if the ordinance is modified to allow for un-shielded, brighter, and ‘cooler ’, lighting, that those modifications would actually have a negative effect on public safety, according to the scientific literature on this subject. Furthermore, Palo Alto’s Police Department was consulted by the City regarding the standard of 2700 Kelvin for lighting fixtures, and found that threshold acceptable for public safety. 3. The ordinance as written establishes clear precedence for state and federal laws. The letter from Stanford makes the following claim. “We are also concerned about potential conflicts with California Title 24 and Cal/OSHA lighting\ requirements. These state and federal standards may supersede local regulations, rendering parts of the proposed ordinance unenforceable. We urge the City to carefully evaluate these overlaps to avoid legal and practical inconsistencies.” The letter does not identify any specific conflicts with state or federal law in the ordinance as written. Furthermore, the ordinance contains language that already addresses these concerns in the following section. “(i) Additional Provisions and Conflict Precedence. Lighting required by the Building Code, Fire Code, or state or federal law shall additionally comply with the requirements of this section, unless these requirements necessarily conflict with the aforementioned Codes and laws. In the event of a conflict, the standards in the applicable Codes and laws shall prevail.” Since no specific conflicts with state or federal laws have been identified, and the ordinance clearly establishes the precedence of state and federal laws, we believe no modifications to the draft are necessary at this time to address this topic. Should unforeseen conflicts arise after adoption, the ordinance is already equipped to address them. sierraclub.org/loma-prieta ~ 3921 East Bayshore Road, Suite 204, Palo Alto, CA 94303 In Conclusion We hope that our explanations provide sufficient justification that the draft ordinance is already equipped to resolve the concerns from Stanford noted above. Sincerely, Dashiell Leeds Conservation Coordinator Sierra Club Loma Prieta Chapter sierraclub.org/loma-prieta ~ 3921 East Bayshore Road, Suite 204, Palo Alto, CA 94303 From:Victoria S. Ramirez To:Council, City Cc:Cha, Kelly; Molly Swenson (SHC) Subject:SHC Comment Letter: Item 8 - Lighting Ordinance (11/10/25) Date:Friday, November 7, 2025 4:35:22 PM Attachments:image001.png Lighting Ordinance SHC Comment Letter - 11-7-25 FINAL.pdf CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. Dear Honorable Mayor and members of the City Council, Attached you will find a letter from Stanford Health Care providing feedback and expressing our concerns with Item 8 on the November 10 Council Meeting Agenda –Proposed Lighting Ordinance. Please feel free to reach out if you have any questions. Sincerely, Victoria VICTORIA S. RAMIREZ, MPA she/her/hers Director of State and Local Government Affairs Stanford Health Care Office of Government Affairs – Stanford University 1840 Embarcadero Road Palo Alto, CA 94303 cell: 650-374-8729 vsramirez@stanford.edu mailing address: 300 Pasteur Drive, M/C 5539, Stanford, CA 94305 Office of Government Affairs Confidentiality notice: This communication and any attachments may contain confidential or privileged information for the use by the designated recipient(s) named above. If you are not the intended recipient, you are hereby notified that you have received this communication in error and that any review, disclosure, dissemination, distribution or copying of it or the attachments is strictly prohibited. If you have received this communication in error, please contact me and destroy all copies of the communication and attachments. Thank you. November 7, 2025 Palo Alto City Council City of Palo Alto 250 Hamilton Avenue Palo Alto, CA 94301 Re: City Council Consideration of Proposed Lighting Ordinance VIA EMAIL city.council@paloalto.gov; kelly.cha@paloalto.gov Dear Mayor Lauing and Members of the City Council, Stanford Medicine appreciates the opportunity to provide feedback on the current iteration of the proposed Lighting Ordinance. As it relates to our medical campus, we have several concerns with the proposal, particularly related to applicability, safety, implementation costs, and compliance timeline. We were invited to attend the virtual outreach meeting with Planning staff in October . Based on the verbal comments from our organization and others, there is an overall alignment on concerns and the notion that the business community at large has not been adequately engaged by the City in the crafting of the ordinance compared to proponents of the policy. Based on the review of the most current information, our organization will have great difficulty on multiple fronts in achieving compliance. With respect to applicability, we assert that the ordinance should be targeted to areas where excessive light has the greatest impact. Considering regulations in other jurisdictions, these would mainly be in hillside and coastal areas; in the City, the Foothills and the Baylands are prime candidates. Urban environments, such as our medical campus, are inherently expected to have additional light for safety and operational purposes. Regarding safety, as noted by many in October’s outreach meeting, this is a primary concern. As our campus includes hospital uses, our operations run 24/7 and, consequently, adequate lighting is critical. Internally, prior to recent implementation of exterior lighting upgrades on our campus, we received regular comments from our medical staff that they did not feel safe traversing through the walkways and parking lots on our campus during the nighttime. In addition, we have emergency vehicles, patients, and visitors that rely on our nighttime lighting to navigate to their destinations in an expedient manner. Having to reduce our current overall light output through the measures recommended (motion sensors, shrouding, etc.) would represent a step backward in terms of nighttime safety . Another comment we echo from the business community is that implementation costs would pose an undue burden on our organization. Implementation would not just constitute the replacement of existing features (i.e. replacing the head of a parking lot light); it would include costly wholesale site lighting redesigns, requiring new light poles, trenching, and landscape restoration. It has been noted by staff that implementation costs for businesses have not been assessed. Having recently engaged in a parking l ot lighting upgrade at our 900 Welch Road facility which required significant trenching and installation of new poles, we are aware that lighting installation / modification costs—even for a small property--can cost hundreds of thousands of dollars. Given this is a small sample of our campus, the costs of having to make wholesale changes across the board in a five-year timeframe would be unreasonable. Finally, the currently proposed ordinance includes a compliance timeline in which all of our lighting would need to meet the new code requirements in five years. This timeline places further financial and operational strain on our organization. For example, additional funds and resources would need to be expended within five years on the new installation at 900 Welch Road to achieve code compliance. We would ask that the City allow existing lighting to have legal non-conforming status and that the ordinance only apply to new construction projects. We appreciate your time and consideration of our concerns. We would like to request a continuation of this item so that comments from us and others in the business community can be thoroughly assessed by staff and City Council. Please do not hesitate to contact me at vsramirez@stanford.edu if any questions arise. Sincerely, Victoria S. Ramirez Molly Swenson Director of State and Local Government Affairs Director of Land Use & Licensing Stanford Health Care Stanford Medicine From:Diane McCoy To:Council, City Subject:Fw: Dark Skies Ordinance Date:Friday, November 7, 2025 4:24:53 PM CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. i ----- Forwarded Message ----- From: Diane McCoy <dianemccoy10@comcast.net> To: city.council@cityofpaloalto.gov <city.council@cityofpaloalto.gov> Sent: Friday, November 7, 2025, 04:16:57 PM PST Subject: Dark Skies Ordinance Dear Palo Alto City Council. Thank you very much for your hard work and service. I have a resident of Palo Alto since 1978. I live in the Duveneck/St. Francis neighborhood of the city. I am writing regarding the Dark Skies Ordinance up for discussion on Monday, Nov. 1 city council meeting. Please adopt a STRONG outdoor lighting ordinance. A strong ordinance would protect birds, people and our night sky. Please incorporate the suggestions from the SCVBird Alliance and the Sierra Club in the ordinance. Have you had a chance to see some of the comments people have written in response to the Palo Alto Weekly's article about the ordinance: "Dark skies are important to human health because they support a balanced circadian rhythm, improved sleep, hormones and metabolism. Minimally, lightg should be down lit, and softer, rather than blinding white spots lights. " Education for motion detection lights would be excellent. Many have these; they are cost effective and efficient. We have our phones with us all the time; equipped with flashlights! Thank you for your consideration of this situation. Best, Diane McCoy This message needs your attention This is a personal email address. Mark Safe Report Powered by Mimecast Greer Road From:Victoria S. Ramirez To:Council, City Cc:Cha, Kelly; Molly Swenson (SHC) Subject:SHC Letter of Support Item 8 - Lighting Ordinance (11/10/25) Date:Friday, November 7, 2025 4:13:38 PM Attachments:image001.png Lighting Ordinance SHC Comment Letter - 11-7-25 FINAL.pdf CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. Dear Honorable Mayor and members of the City Council, Attached you will find a letter from Stanford Health Care providing feedback and expressing our concerns with Item 8 on the November 10 Council Meeting Agenda –Proposed Lighting Ordinance. Please feel free to reach out if you have any questions. Sincerely, Victoria VICTORIA S. RAMIREZ, MPA she/her/hers Director of State and Local Government Affairs Stanford Health Care Office of Government Affairs – Stanford University 1840 Embarcadero Road Palo Alto, CA 94303 cell: 650-374-8729 vsramirez@stanford.edu mailing address: 300 Pasteur Drive, M/C 5539, Stanford, CA 94305 Office of Government Affairs Confidentiality notice: This communication and any attachments may contain confidential or privileged information for the use by the designated recipient(s) named above. If you are not the intended recipient, you are hereby notified that you have received this communication in error and that any review, disclosure, dissemination, distribution or copying of it or the attachments is strictly prohibited. If you have received this communication in error, please contact me and destroy all copies of the communication and attachments. Thank you. November 7, 2025 Palo Alto City Council City of Palo Alto 250 Hamilton Avenue Palo Alto, CA 94301 Re: City Council Consideration of Proposed Lighting Ordinance VIA EMAIL city.council@paloalto.gov; kelly.cha@paloalto.gov Dear Mayor Lauing and Members of the City Council, Stanford Medicine appreciates the opportunity to provide feedback on the current iteration of the proposed Lighting Ordinance. As it relates to our medical campus, we have several concerns with the proposal, particularly related to applicability, safety, implementation costs, and compliance timeline. We were invited to attend the virtual outreach meeting with Planning staff in October . Based on the verbal comments from our organization and others, there is an overall alignment on concerns and the notion that the business community at large has not been adequately engaged by the City in the crafting of the ordinance compared to proponents of the policy. Based on the review of the most current information, our organization will have great difficulty on multiple fronts in achieving compliance. With respect to applicability, we assert that the ordinance should be targeted to areas where excessive light has the greatest impact. Considering regulations in other jurisdictions, these would mainly be in hillside and coastal areas; in the City, the Foothills and the Baylands are prime candidates. Urban environments, such as our medical campus, are inherently expected to have additional light for safety and operational purposes. Regarding safety, as noted by many in October’s outreach meeting, this is a primary concern. As our campus includes hospital uses, our operations run 24/7 and, consequently, adequate lighting is critical. Internally, prior to recent implementation of exterior lighting upgrades on our campus, we received regular comments from our medical staff that they did not feel safe traversing through the walkways and parking lots on our campus during the nighttime. In addition, we have emergency vehicles, patients, and visitors that rely on our nighttime lighting to navigate to their destinations in an expedient manner. Having to reduce our current overall light output through the measures recommended (motion sensors, shrouding, etc.) would represent a step backward in terms of nighttime safety . Another comment we echo from the business community is that implementation costs would pose an undue burden on our organization. Implementation would not just constitute the replacement of existing features (i.e. replacing the head of a parking lot light); it would include costly wholesale site lighting redesigns, requiring new light poles, trenching, and landscape restoration. It has been noted by staff that implementation costs for businesses have not been assessed. Having recently engaged in a parking l ot lighting upgrade at our 900 Welch Road facility which required significant trenching and installation of new poles, we are aware that lighting installation / modification costs—even for a small property--can cost hundreds of thousands of dollars. Given this is a small sample of our campus, the costs of having to make wholesale changes across the board in a five-year timeframe would be unreasonable. Finally, the currently proposed ordinance includes a compliance timeline in which all of our lighting would need to meet the new code requirements in five years. This timeline places further financial and operational strain on our organization. For example, additional funds and resources would need to be expended within five years on the new installation at 900 Welch Road to achieve code compliance. We would ask that the City allow existing lighting to have legal non-conforming status and that the ordinance only apply to new construction projects. We appreciate your time and consideration of our concerns. We would like to request a continuation of this item so that comments from us and others in the business community can be thoroughly assessed by staff and City Council. Please do not hesitate to contact me at vsramirez@stanford.edu if any questions arise. Sincerely, Victoria S. Ramirez Molly Swenson Director of State and Local Government Affairs Director of Land Use & Licensing Stanford Health Care Stanford Medicine From:John Miller To:Council, City Subject:11/10/25 Agenda Item 8: Please adopt a strong outdoor lighting ordinance Date:Friday, November 7, 2025 1:53:19 PM CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links. Dear Mayor Lauing and Members of the City Council, I am a former resident and frequent visitor to Palo Alto. I’m emailing to ask you to adopt a strong outdoor lighting ordinance to protect wildlife, people and the night sky. Light pollution in and around the Bay Area has become a serious problem that can impact people by disrupting sleep patterns and can interfere with (if not entirely prohibit) the ability to see and appreciate dark skies. I urge you to incorporate into the proposed ordinance best practices from the International Dark-Sky Association and the Illuminating Engineering Society, ensuring that outdoor lighting is shielded, controlled and used only where and when it’s needed without compromising safety or commerce. Thank you for your attention to this most important issue. John Miller Los Gatos From:Annette Herz To:Council, City Subject:11/10/25 Agenda Item 8: Please adopt a strong outdoor lighting ordinance Date:Friday, November 7, 2025 1:44:18 PM CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. i Dear City Council I am a resident, a certified California Naturalist and a docent at several of our local nature preserves. I am also VERY concerned about the state of our local environment and the impact our human activity has on them. As you know the SF Bay Area is a major route for bird migrations - and human population concentrations like the Bay Area Cities can have a disastrous effect on their behaviour. I noticed even on a much smaller scale the impact (less visitors) my backyard has since the neighbor behind the fence has installed security lights. Less skunks, less raccoons, less fox - but more non-native rats. For the bird population our city lights is MUCH more dangerous - it can confuse their navigation and lead to avoidance and mistakes that impact not only the single birds, but future generations (a bird that dies on migration will not reproduce..). With that we have a huge responsibility - and I hope that my city of Palo Alto followed the good example of other cities - and the suggestions set forward by the Bird Alliance and the Sierra Club (both formidable local leaders against climate change and for nature conservation) and PLEASE ADOPT THE STRONGEST ORDINANCE TO PROTECT BIRDS, HUMANS and our NIGHT SKY. Thanks for making me a proud resident Annette Herz -- - Annette This message needs your attention This is a personal email address. This is their first email to your company. Mark Safe Report From:ROBERT HIRT To:Council, City Subject:City Council 11/10 meeting:Agenda item 8 Date:Friday, November 7, 2025 1:19:34 PM CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links. Dear Council: Please adopt a strong outdoor lighting ordinance and use the suggestions from the Santa Clara Valley Bird Alliance. Dark skies are very important to protect the many species of birds that migrate primarily at night. Bright lights confuse and disorient them often causing collisions with buildings. I addition dark skies produce a more restful condition which produces better sleep for our people. It has been shown (by the Cleveland Clinic) that better sleep (a full 8 hrs) is important for keeping immune systems well and which help prevent diseases like cancer from developing. For the health and happiness of our community please adopt a strong outdoor lighting ordnance. Very truly yours, Bob Bob Hirt Bobhirt@aol.com (408) 821-2732 Please excuse the brevity, the typos, and the sometimes humorous autocorrect changes. From:Margaret Hinebaugh To:Council, City Subject:11/10/25 Agenda Item 8: Please adopt a strong outdoor lighting ordinance Date:Friday, November 7, 2025 11:18:47 AM CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. i Hello, I strongly urge the Palo Alto City Council to adopt a strong lighting ordinance to protect birds, people, and our night sky from light pollution. Light pollution harms wildlife and ecosystems, and it disrupts humans' natural circadian rhythms, which has negative impacts on our health. Nighttime lighting is wasteful and unnecessary; we do not need a string of bright, outdoor lights on at every house 24/7. There is no good evidence that increased lighting reduces total crime. Please incorporate the dark sky/outdoor lighting suggestions from the Santa Clara Valley Bird Alliance and the Sierra Club in the ordinance. Thank you, Margaret Hinebaugh (408) 247-8474 This message needs your attention This is a personal email address. This is their first email to your company. Mark Safe Report From:mark conover To:Council, City Subject:11/10/25 Agenda Item 8: Outdoor Lighting Ordinance Date:Thursday, November 6, 2025 11:17:45 PM CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links. Congratulations on your proposed updated Lighting Ordinance. I have assisted in writing our Santa Cruz lighting ordinance which we submitted to our Mayor in June. Hopefully we will be following in your footsteps. Following a quick review, I have some comments: Edgewood Drive Exemption: As Edgewood Drive borders the sensitive San Fransquito Creek Riparian area, the light limits should not be exempted but if anything strengthened. Our Santa Cruz Lighting Ordinance attempts to limit light trespass on the San Lorenzo River to “unmeasureable”. You should definitely prohibit unapproved luminaires on properties adjacent to the river. A super-bright LED wall pack would be very disruptive to the birds, amphibians, beavers, insects, fish and all other living organisms including the Steelhead Trout and Red Legged Frogs. Regarding security concerns, the 1 lux limit should be adequate for modern security cameras. And motion detection lights would highlight trespasser in the yards. Shorten compliance period for easily adjustable lights I suggest shortening the compliance to one year for easily adjustable lights. People tend to procrastinate work until last minute. I doubt that this change would be too much of a burden on the residents. Blanco Texas allowed existing luminaires to be grandfathered in compliance until they were repaired or replaced. Twelve years later “few if any grandfathered lights were voluntarily brought into compliance.” The town passed a new ordinance with a firm date for compliance Ordinance Name We started developing a “DarkSky” ordinance but quickly decided to rename it as an “Outdoor Lighting Ordinance”. DarkSky lighting implies limiting lighting toward the sky. But in addition, it is important to limit the light below the horizontal to prevent glare in the eyes of pedestrians, bicyclists, drivers and all living things. Mark Conover Santa Cruz CA From:Timothy Lee To:Council, City Subject:11/10/25 Agenda Item 8: Please adopt a strong outdoor lighting ordinance Date:Thursday, November 6, 2025 10:34:43 PM CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. i Hello Mayor Lauring and Palo Alto city council, My name is Timothy Lee, a local highschool junior. I, alongside the fushd climate collective and the Santa Clara Valley bird alliance are calling for the strengthening of the dark sky policy in the the city of Palo Alto. I view light pollution to be a harmful force to our society and ecosystem that often goes unrecognized. Light pollution dilutes the night sky, stripping many childhoods from being able to truly experience the stars, limit local astronomical research, and also affects health, causing insomnia, depression, and in some cases, cancer too. This cause can be prevented by the Dark Sky policies strengthening, a relatively low cost policy for a high reward. Please take this matter into consideration. Sincerely, Timothy Lee This message needs your attention This is a personal email address. This is their first email to your company. Mark Safe Report From:Kenneth Low To:Council, City Subject:Proposed Outdoor Lighting Ordinance Date:Thursday, November 6, 2025 7:44:23 PM CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. i Dear Honorable Mayor and Members of the City Council, With respect to the proposed lighting ordinance, we are writing in support of the Edgewood Neighborhood Alliance and the following: We support the exemption of homes on the creek-side of Edgewood Drive given their unique circumstances, including encampments in the creek, crime and proximity to East Palo Alto, which has no barriers to enter the creek. The exemption for Edgewood properties contains an error and should be corrected to the following: “(7) Single family residential sites adjacent to San Francisquito Creek and fronting on Edgewood Drive if the portion of the site subject to a permanent easement in favor of the Santa Clara Valley Water District (or its successor in interest) for flood control purposes is reconfigured after January 1, 2002. These sites shall be subject to the requirements under Section 18.40.250(e)(4)(A).” Thank you. Kenner Low Sent from my iPhone This message needs your attention This is a personal email address. This is their first email to you. Mark Safe Report From:Sherry Listgarten To:Council, City; Cha, Kelly Subject:Strongly in favor of dark(er) skies Date:Thursday, November 6, 2025 7:35:31 PM CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. Dear City Council and Staff, I am very supportive of stronger limits on outdoor lighting, which you will be considering on November 10. Light pollution is bad for our health and that of birds, insects, and the fauna that depend on them. Many essential natural behaviors like breeding, foraging, and migration rely on dark nights. But too many of our streets and yards are now unnecessarily lit up at all hours. This is a relatively new phenomenon for our city. The pervasiveness of LED lighting has caused Palo Alto to become much lighter at night, with an almost industrial-quality tone. LED lights are inexpensive to operate and often blue-ish in color, which is leading to unhealthy levels of outdoor light pollution. A good ordinance will get us back to our more natural norm, at least over time. I agree with the Sierra Club and SCV Bird Alliance that the ordinance should apply to all new and replacement lighting, but not to existing fixtures that would not otherwise need replacing. I also agree that a one-year (and not two-year) heads-up period of education about adjusting timers/angles/etc should be sufficient, particularly since enforcement will largely consist of more education anyway. One thing I would suggest is to consider a shut-off period of 11pm or 11:30pm rather than midnight, simply because midnight is difficult for a lot of people to set correctly on timers. This is a relatively small but powerful and hopefully visible thing that Palo Alto can do to better support the people and the wildlife in our city. Thank you, -- Sherry. From:Daniel Hansen To:Council, City; Lauing, Ed; Cha, Kelly Cc:Francois, Matthew; Lait, Jonathan; Armer, Jennifer; Shikada, Ed; Stump, Molly; Cha, Kelly Subject:Proposed Lighting Ordinance (18.40.250) Date:Thursday, November 6, 2025 4:35:37 PM Attachments:Letter Regarding Lighting Ordinance - Edgewood Exemption.pdf CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. i Dear Honorable Mayor, Members of the City Council and Ms. Cha, Please see the attached letter submitted on behalf of the Edgewood Neighborhood Alliance regarding the Proposed Lighting Ordinance (18.40.250). Best regards, Daniel Hansen This message needs your attention This is their first mail to some recipients. Mark Safe Report Powered by Mimecast Via Email [City.Council@CityofPaloAlto.org; Ed.Lauing@CityofPaloAlto.org; kelly.cha@paloalto.gov] November 6, 2025 Honorable Mayor and Members of the City Council and Kelly Cha City of Palo Alto 250 Hamilton Avenue Palo Alto, CA 94301 Re: Updating Section 18.40.250 (Lighting), Amending Chapters 18.10, 18.12, 18.28, and Section 18.40.230 of Title 18; Agenda Item # 8 City Council, Regular Meeting, November 10, 2025 Dear Honorable Mayor and Members of the Palo Alto City Council and Ms. Cha: At the City Council meeting on April 7, 2025, the Council unanimously agreed that the creek-side properties on Edgewood Drive should be excluded from the security elements of the proposed lighting ordinance due to their unique circumstances, including encampments in San Francisquito Creek and proximity to East Palo Alto. The revised ordinance in Staff’s report includes this exemption; however, it contains an error. As drafted, only 15 of the 52 properties on Edgewood Drive would be excluded. Specifically, the “if” language that refers to reconfiguring a portion of the site subject to a 2002 easement has no bearing in this context and would unfairly restrict the exemption. Here is the error: (7) Single family residential sites adjacent to San Francisquito Creek and fronting on Edgewood Drive if the portion of the site subject to a permanent easement in favor of the Santa Clara Valley Water District (or its successor in interest) for flood control purposes is reconfigured after January 1, 2002. These sites shall be subject to the requirements under Section 18.40.250(e)(4)(A). The added language was apparently copied from the City’s fencing ordinance (PAMC 16.24.020(d)) where the flood control context is relevant. It should be removed so that the Council’s intent can be accomplished. Respectfully, EDGEWOOD NEIGHBORHOOD ALLIANCE By, its representative, _____________________ Daniel Hansen cc: Matthew D. Francois, Rutan & Tucker, LLP Jonathan Lait, Director of Planning & Development Services Jennifer Armer, Assistant Director of Planning & Development Services Ed Shikada, City Manager Molly Stump, City Attorney From:Dashiell Leeds To:Council, City; Burt, Patrick; Lauing, Ed; Lu, George; Lythcott-Haims, Julie; Reckdahl, Keith; Stone, Greer; Veenker, Vicki; Cha, Kelly; Clerk, City Cc:shani@scvbirdalliance.org; James Eggers; Mike Ferreira; Gita Dev; Lait, Jonathan; Armer, Jennifer; Frick, Coleman Subject:SCLP and SCVBA Comments on Nov 10 Draft Dark Sky Ordinance Date:Thursday, November 6, 2025 4:10:39 PM Attachments:SLCP SCVBA joint letter to Palo Alto re Dark Sky Ordinance Nov 10, 2025.pdf CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. Dear Mayor Lauing and Palo Alto City Councilmembers, The Santa Clara Valley Bird Alliance and the Sierra Club Loma Prieta Chapter support the adoption of Palo Alto’s Dark Sky (Outdoor Lighting) Ordinance, and suggest a few critical corrections. We appreciate the extensive work by City staff, and the clear direction from the Planning and Transportation Commission and Council to develop a measure that protects migratory birds, nocturnal wildlife, and human health while conserving energy and restoring the City’s night sky. The ordinance follows best practices from DarkSky International and the Illuminating Engineering Society by ensuring that lighting is shielded, directed, and used only where and when needed. Please consider incorporating the following four requests: Amend Section 18.40.250(c)(3) to remove the phrase “If a building permit is required” to apply the ordinance to all new installation, replacement, or modification of outdoor luminaires, Amend Section 18.40.250(d)(7) to ensure that prohibited lighting types are not allowed in the exempted Edgewood Drive properties, Remove 18.40.250(L)(2)(A)(B), removing retrofit requirements for existing outdoor lighting, and Retain and shorten the compliance period in Section 18.40.250(L)(1) for easily adjustable existing lighting fixtures to one year. Please read the attached letter for more details regarding our suggested improvements. Sincerely, Shani Kleinhaus Environmental Advocate Santa Clara Valley Bird Alliance Dashiell Leeds Conservation Coordinator Sierra Club Loma Prieta Chapter SAN MATEO, SANTA CLARA & SAN BENITO COUNTIES November 6, 2025 Palo Alto City Council 250 Hamilton Ave Palo Alto, CA 94301 Re: November 10 Agenda Item 8 - Dark Sky (Outdoor Lighting) Ordinance Dear Mayor Lauing and Palo Alto City Councilmembers, The Santa Clara Valley Bird Alliance and the Sierra Club Loma Prieta Chapter support the adoption of Palo Alto’s Dark Sky (Outdoor Lighting) Ordinance, and suggest a few critical corrections. We appreciate the extensive work by City staff, and the clear direction from the Planning and Transportation Commission and Council to develop a measure that protects migratory birds, nocturnal wildlife, and human health while conserving energy and restoring the City’s night sky. The ordinance follows best practices from DarkSky International and the Illuminating Engineering Society by ensuring that lighting is shielded, directed, and used only where and when needed. Please consider incorporating the following four requests: ● Amend Section 18.40.250(c)(3) to remove the phrase “If a building permit is required” to apply the ordinance to all new installation, replacement, or modification of outdoor luminaires, ● Amend Section 18.40.250(d)(7) to ensure that prohibited lighting types are not allowed in the exempted Edgewood Drive properties, ● Remove 18.40.250(L)(2)(A)(B), removing retrofit requirements for existing outdoor lighting, and ● Retain and shorten the compliance period in Section 18.40.250(L)(1) for easily adjustable existing lighting fixtures to one year. Request #1 Amend Section 18.40.250(c)(3) to remove the phrase “If a building permit is required” to apply the ordinance to all new installation, replacement, or modification of outdoor luminaires. Current text (3) If a building permit is required: New installation of outdoor luminaires, replacement of existing outdoor luminaires, or modifications to the lighting type or system. Proposed Text (3) If a building permit is required: New installation of outdoor luminaires, replacement of existing outdoor luminaires, or modifications to the lighting type or system. Justification Both the Planning and Transportation Commission (October 30, 2024) and the City Council (April 7, 2025) explicitly directed that the lighting standards apply to all new and replacement outdoor lighting. The April 7th City Council minutes1 and the staff report for Item 8 confirm this directive, yet the draft ordinance retains the inconsistent “building permit” qualifier. Limiting applicability to projects requiring a building permit creates a major loophole that exempts most fixture replacements and new lighting installations. Since lighting installations do not typically require permits, much new and replacement lighting would remain unregulated. Removing the “building permit” qualifier will bring the ordinance into alignment with Council direction and ensure it functions as intended. Request #2 Amend Section 18.40.250(d)(7) to ensure that prohibited lighting types are not allowed in the exempted Edgewood Drive properties. Current Text “(7) Single family residential sites adjacent to San Francisquito Creek and fronting on Edgewood Drive if the portion of the site subject to a permanent easement in favor of the Santa Clara Valley Water District (or its successor in interest) for flood 1 https://cityofpaloalto.primegov.com/Public/CompiledDocument?meetingTemplateId=16025&compileOutpu tType=1 control purposes is reconfigured after January 1, 2002. These sites shall be subject to the requirements under Section 18.40.250(e)(4)(A).” Proposed Text (7) Single family residential sites adjacent to San Francisquito Creek and fronting on Edgewood Drive if the portion of the site subject to a permanent easement in favor of the Santa Clara Valley Water District (or its successor in interest) for flood control purposes is reconfigured after January 1, 2002. These sites shall be subject to the requirements under Sections 18.40.250(e)(4)(A) and 18.40.250(g). Justification While we appreciate that Section 18.40.250(e)(4)(A) applies the lighting curfew, the exemption in (d)(7) inadvertently allows the use of prohibited lighting such as blinking, flashing, or rotating lights, and searchlights, aerial lasers, or spotlights, all forms of illumination that are unnecessary for safety and highly disruptive to wildlife. Safety can be achieved using fully shielded, dark-sky-compliant luminaires. Extending the prohibited lighting clause to this area will prevent excessive glare and protect one of Palo Alto’s most sensitive riparian corridors along San Francisquito Creek. Request #3 Remove retrofit requirements in (L)(2) for existing outdoor lighting. Current Text (Section 18.40.250(L)) “(L) Existing Nonconforming Lighting (1) Within two years of [the effective date of this ordinance]: Where existing outdoor luminaires have the ability to adjust (through existing dimmers, directional adjustability, timers, etc.), the requirements under Section 18.40.140(e), except for the shielding requirements under subsection 18.40.140(e)(1), shall apply. (2) For all existing outdoor luminaires, the requirements under Section 18.40.140(e) shall apply within the following timeframes from [the effective date of this ordinance]: (A) Residential and Mixed Use Zoning Districts: Within ten years. (B) Nonresidential Zoning Districts: Within five years. Proposed Revision Keep (L)(1) to retain the requirement that all easily-adjustable luminaires be adjusted to be compliant with the ordinance. We recommend adjusting the timing window of (l)(1), as described below in Request #4. Delete subsections (L)(2)(A) and (B), removing the retrofit schedule. (2) For all existing outdoor luminaires, the requirements under Section 18.40.140(e) shall apply within the following timeframes from [the effective date of this ordinance]: (A) Residential and Mixed Use Zoning Districts: Within ten years. (B) Nonresidential Zoning Districts: Within five years. Justification Requiring retrofits for all existing lighting would be difficult to administer and monitor, and can create hardship for residents and businesses. Applying the ordinance to all new, replacement, and easily-modified lighting would achieve gradual citywide compliance through equipment turnover while avoiding confusion and unnecessary administrative burden. Retaining the hardship exemption (Section 18.40.250(j)) and clear applicability to all new and replacement lighting ensures that future installations meet dark-sky standards without imposing mandatory retrofits on existing luminaires. Request #4 Shorten the compliance period for easily adjustable existing lighting fixtures. Current Text (Section 18.40.250(L)(1)) “(1) Within two years of [the effective date of this ordinance]: Where existing outdoor luminaires have the ability to adjust (through existing dimmers, directional adjustability, timers, etc.), the requirements under Section 18.40.140(e), except for the shielding requirements under subsection 18.40.140(e)(1), shall apply.” Proposed Text “(1) Within one year of [the effective date of this ordinance]: Where existing outdoor luminaires have the ability to adjust (through existing dimmers, directional adjustability, timers, etc.), the requirements under Section 18.40.140(e), except for the shielding requirements under subsection 18.40.140(e)(1), shall apply.” Justification A two-year grace period is unnecessarily long for fixtures that can be corrected through simple adjustments such as dimming, re-aiming, or resetting timers. Comparable Dark Sky ordinances, including Brisbane’s, require compliance within one year. A one year window provides sufficient time for the City to distribute educational materials and for property owners to make straightforward adjustments, achieving measurable reductions in light pollution much sooner. In Conclusion With the brief but critically important modifications we have suggested, Palo Alto’s dark sky ordinance will reduce light pollution over time and improve public health and public safety and protect migratory birds and wildlife. The provisions of this ordinance are in line with successfully adopted dark sky ordinances throughout the nation. The requirements are extremely flexible, ensuring that business in Palo Alto will not be impeded, and are robust enough to protect residents and wildlife from the dangers of over-lighting. Please move to adopt this ordinance, with the modifications we have suggested. Sincerely, Shani Kleinhaus Environmental Advocate Santa Clara Valley Bird Alliance Dashiell Leeds Conservation Coordinator Sierra Club Loma Prieta Chapter From:Shannon McEntee To:Council, City Subject:Agenda Item 8, Please Adopt a Strong Outdoor Lighting Ordinance Date:Thursday, November 6, 2025 10:45:28 AM CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. Dear Mayor Lauing and council members: Being a passionate environmentalist I’ve known for a long time how night light endangers species, including humans! Every night I sleep with an eye coverbecause the street lamp outside my condo building penetrates into my bedroom. Other cities have Dark Sky Ordinances so we are behind in this simpleprotection. Please do the right thing and protect our neighboring species,including me and fellow residents. Our world is changing so fast — we need tokeep up. Thank you for your all your good work in managing our special city. You havemy deep respect and admiration. Sincerely, Shannon Rose McEntee From:Tracy Ferea To:Council, City Subject:Please Pass a Strong Dark Skies Ordinance 11/10/25 Agenda Item 8 Date:Wednesday, November 5, 2025 6:31:52 PM CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. i Dear Council,As a PhD Biologist I would like to ask you to pass a strong scientific based DarkSkies Ordinance. Light pollution is one of the fastest growing and mostpervasive forms of environmental pollution. Scientific research suggests thatlight pollution can have lasting adverse effects on both human and wildlifehealth. My family deals with this pollution nightly as our neighbors and aChurch shine light into our house and yard. Some of the Many Specific Human Health Impacts Sleep disorders: Lack of darkness can lead to sleep deprivation and disorders like insomnia and delayed sleep-phase syndrome. Mental health: It is linked to depression and impaired thinking. Hormonal disruption: Artificial light at night can suppress the production of melatonin, which is essential for regulating metabolism, the immune system, and sleep. Cardiovascular problems: Nighttime light exposure has been linked to higher risks of heart disease, high blood pressure, and increased stress- related activity in the brain. Metabolic issues: Studies have linked light at night to an increased risk of obesity and diabetes. Cancer risk: Lowered melatonin levels, which are a consequence of nighttime light exposure, have been correlated with increased rates of some cancers, such as breast cancer. This message needs your attention No employee in your company has ever replied to this person. This is a personal email address. Mark Safe Report Powered by Mimecast Vision problems: Direct glare from bright, poorly designed lights can impair vision, reduce sensitivity to fine details, and cause safety issues, particularly for the elderly. Melatonin production: Melatonin is a hormone released in the dark that is vital for sleep and has protective health functions. Circadian rhythms: The human body relies on a natural day-night cycle to keep internal rhythms in sync. Artificial light at night disrupts this cycle. Negative Impacts on Wildlife and the Environment Disruption of circadian rhythms: Artificial light can interfere with the natural day- night cycle, affecting the sleep patterns and feeding habits of animals. Misorientation and collisions: Bright lights can confuse migratory animals and birds, leading them off course and into dangerous situations. Altered predator-prey relationships: Artificial light can make nocturnal animals more visible to predators, disrupting their natural patterns. Loss of biodiversity: Light pollution can drive away sensitive wildlife species, reducing the biodiversity of ecosystems. Altered plant growth: Artificial light can affect the growth and flowering patterns of plants, potentially disrupting plant-animal interactions. Increased leaf toughness: Leaves exposed to artificial light at night are often physically tougher and more difficult for insects to chew, disrupting the basis of the food web. Resource allocation: Plants may shift resources from producing nutrient-rich leaves to supporting structural compounds, leading to lower nutrient levels in leaves decreasing the nutrient value in the food web. Light pollution poses a significant threat to both ecosystems and human health. The good news is that you as council members have the power to reduce its impact and improve both our health and that of our environment. It is time to take action now and bring back the darkness for a healthier, more sustainable future for us all. Sincerely, Tracy Ferea, PhD From:Niu, Isabelle To:Council, City Subject:11/10/25 Agenda Item 8: Please adopt a strong outdoor lighting ordinance Date:Wednesday, November 5, 2025 4:32:02 PM CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. i Hi Palo Alto City Council, My name is Isabelle Niu and I am a high school junior in the Bay Area. As a student deeply interested in astronomy and our environment, I wanted to advocate for the adoption of a strong lighting ordinance to protect birds, people, and our night sky. Being someone who loves to visit Palo Alto facilities (Palo Alto library, Stanford mall, etc.), I've noticed that while the city already does better than many areas in limiting skyglow, there are still places where lights are brighter than needed or shine upward rather than toward the ground. Some fixtures also illuminate trees directly, which can disrupt their natural growth cycles and harm overall plant health. Simple changes like setting standards for adding shielding, lowering brightness, and ensuring lights point only where illumination is needed can maintain safety while reducing unintended environmental impacts. Thank you so much for your time and consideration. Warm regards, Isabelle Niu This message needs your attention No employee in your company has ever replied to this person. Mark Safe Report Powered by Mimecast From:Michael Hindery To:Council, City Subject:11/10/25 Agenda item 8: please adopt a strong outdoor lighting ordinance Date:Wednesday, November 5, 2025 3:09:06 PM CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. i Hi -- I am a 30 year Palo Alto resident and am writing to urge the Council pass a strong outdoor lighting ordinance at next week's meting. We need the Dark Sky Ordinance to reduce light pollution and maintain the ability to see the stars. Thank you. Michael Hindery m: 650-740-0004 This message needs your attention This is a personal email address. This is their first email to you. Mark Safe Report From:Kay Bushnell To:Council, City Subject:11/10/25 Agenda item 8 Date:Wednesday, November 5, 2025 12:45:04 PM Dear Mayor Lauing and members of the Palo Alto City Council, Please establish a strong Dark Sky Ordinance (outdoor lighting ordinance). It is an important way to benefit both human and wildlife well-being. We must prevent Palo Alto's natural darkness from being polluted with unhealthy artificial lighting. Please remember that we are city that often serves as a role model for other communities. Our strong Dark Sky Ordinance may benefit them, too. Thank you, Kay Bushnell Palo Alto, CA From:Cha, Kelly To:Tiffany Griego; Council, City; Clerk, City Cc:Shweta Bhatnagar; Diana O"Dell; Jean G. Snider; Kelly Kline; Jamie S. Jarvis; Inglis, Jim Subject:Re: Stanford Comments: 11/10/25 City Council Hearing on the Lighting Ordinance Update Date:Wednesday, November 5, 2025 11:51:55 AM Attachments:Outlook-a1naulif.png Hi Ms. Griego, Thank you for taking time and submitting comments. This email acknowledges that the City received your comments and that your comment letter will be shared as part of the public comments for the upcoming hearing on 11/10. Thanks, Kelly Cha (she/her) Senior Planner Planning and Development Services (650) 329-2155 | Kelly.Cha@PaloAlto.gov www.PaloAlto.gov From: Tiffany Griego <tgriego@stanford.edu> Sent: Tuesday, November 4, 2025 2:24 PM To: Cha, Kelly <Kelly.Cha@paloalto.gov>; Council, City <city.council@PaloAlto.gov>; Clerk, City <City.Clerk@PaloAlto.gov> Cc: Shweta Bhatnagar <shwetab@stanford.edu>; Diana O'Dell <dodell@stanford.edu>; Jean G. Snider <jsnider@stanford.edu>; Kelly Kline <khkline@stanford.edu>; Jamie S. Jarvis <jjarvis@stanford.edu>; Inglis, Jim <jinglis@stanford.edu> Subject: Stanford Comments: 11/10/25 City Council Hearing on the Lighting Ordinance Update CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. Dear Mayor Lauing and Members of the City Council, Please find enclosed Stanford University’s comments related to the Dark Sky Lighting Ordinance as it affects Stanford Research Park. Thank you in advance for your efforts to respond to these comments. Respectfully submitted, Tiffany Griego Senior Managing Director, Stanford Research Park Take advantage of our transportation programs: www.SRPgo.com, a service of Stanford Research Park From: Cha, Kelly <Kelly.Cha@paloalto.gov> Sent: Friday, October 31, 2025 10:54 AM Cc: Cha, Kelly <Kelly.Cha@paloalto.gov> Subject: 11/10/25 City Council Hearing on the Lighting Ordinance Update Hi everyone - Thank you for your continued interest and participation in the Lighting Ordinance Update effort. The Lighting Ordinance Update item is scheduled for the upcoming City Council Hearing on November 10, 2025. Please review the staff report and associated attachment from the City Council Meeting Agenda page here. The Lighting Ordinance Update is Item #8 on the agenda. Please review the PUBLIC COMMENTS section of the agenda to find out how to send your written comments in advance of the meeting, and how to participate and provide your comments orally in- person and virtually. As always, if you have any questions or problem accessing the staff report and associated attachments for the Lighting Ordinance Update item, please do not hesitate to contact me. Thanks again for your continued interest and participation in this effort, Kelly Cha (she/her) Senior Planner Planning and Development Services (650) 329-2155 | Kelly.Cha@PaloAlto.gov www.PaloAlto.gov From:karendrohde@gmail.com To:Council, City; Council, City Subject:11/10/25 Agenda Item 8: Please adopt a strong, science-based Dark Sky Ordinance Date:Wednesday, November 5, 2025 6:51:06 AM CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. i Dear Mayor Lauing and City Council Members, I urge you to adopt a Dark Sky (outdoor lighting) Ordinance. Establishing this ordinance would help protect migrating birds, nocturnal wildlife, and human health, while saving energy and restoring our view of the stars. Artificial light at night affects every level of food webs and ecosystems. We are located on the Pacific Flyway used by migrating birds. Artificial light disorients them, drawing them into urban areas when collisions are often fatal. Insects are irresistibly drawn to lights, where they circle until they die of exhaustion. Because insects are vital prey for birds and other wildlife, insect declines ripple up the food web. Controlling outdoor lighting can reduce bird and insect mortality and restore healthier ecosystems along the Pacific Flyway. Artificial light harms people too. Artificial light at night disrupts sleep, mood, and hormone balance, and has been linked to insomnia, depression, metabolic disease, and cancer risks. Glare from over-lighting can make streets less safe by reducing contrast and night vision. I live in the Palo Verde neighborhood of Palo Alto in a community of Eichler Houses. The houses have beautiful ceiling to floor glass windows as exterior walls. At night, the lights from my neighbor’s back yard aim upwards and towards our house. They are so bright -- all the trees are “lit up” and it looks like a spotlight is aimed over the fence and into our windows. After the neighbors go to bed, these lights are set to go off as motion sensors. When something moves in their yard at night, I get woken by the glaring light coming through my windows. Besides interrupting my sleep, it can’t be good for the other living creatures in the neighborhood. This message needs your attention Some Recipients have never replied to this person. This is a personal email address. Mark Safe Report I hope you will consider all the health benefits, energy savings, and safety attributes of adopting the best practices from the International Dark-Sky Association and the Illuminating Engineering Society. Warm regards, Karen Rohde 3360 Thomas Drive, Palo Alto, CA 94303 2025-2026 President, The Woman’s Club of Palo Alto Past President, the Rotary Club of Palo Alto Sent from Outlook From:Peter Coughlan To:Council, City Subject:11/10/25 Agenda item 8: please adopt a strong outdoor lighting ordinance Date:Tuesday, November 4, 2025 7:45:09 PM CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links. I live on Mariposa Avenue. A street lamp shines directly into my bedroom, even through a dark cloth curtain. I understand the benefit of street lamps (reduced crime, safe walking, etc., but perhaps Palo Alto could adopt lampshades that keep the cone of light from spreading so broadly, and lamps that are a bit gentler on the eyes. Thanks for your consideration, Peter Coughlan Homeowner Mariposa Avenue From:Carolyn Davidson To:Council, City Subject:11/10/25 Agenda Item 8: Please adopt a strong outdoor lighting ordinance Date:Tuesday, November 4, 2025 6:51:51 PM CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. i Dear members of the Palo Alto City Council, I am a Palo Alto resident, a grandparent, a birding enthusiast, and someone interested in the constellations. I urge you to pass a strong, science-based ordinance to protect birds (and people) and to make the constellations a bit more visible from my yard, where I enjoy trying to find them after dark. I'd love to introduce my grandchildren to the stars, their patterns, and the stories behind the constellations. A little less ambient light would be a big help! Looking forward to learning that you've passed a strong outdoor lighting ordinance. Best regards, Carolyn Davidson 1919 Barbara Drive Palo Alto. 94303 This message needs your attention This is a personal email address. This is their first email to you. Mark Safe Report From:Tiffany Griego To:Cha, Kelly; Council, City; Clerk, City Cc:Shweta Bhatnagar; Diana O"Dell; Jean G. Snider; Kelly Kline; Jamie S. Jarvis; Inglis, Jim Subject:Stanford Comments: 11/10/25 City Council Hearing on the Lighting Ordinance Update Date:Tuesday, November 4, 2025 2:25:12 PM Attachments:2025-11-04__ Comment Ltr Dark Sky Ordinance - Stanford University.pdf CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. Dear Mayor Lauing and Members of the City Council, Please find enclosed Stanford University’s comments related to the Dark Sky Lighting Ordinance as it affects Stanford Research Park. Thank you in advance for your efforts to respond to these comments. Respectfully submitted, Tiffany Griego Senior Managing Director, Stanford Research Park Take advantage of our transportation programs: www.SRPgo.com, a service of Stanford Research Park From: Cha, Kelly <Kelly.Cha@paloalto.gov> Sent: Friday, October 31, 2025 10:54 AM Cc: Cha, Kelly <Kelly.Cha@paloalto.gov> Subject: 11/10/25 City Council Hearing on the Lighting Ordinance Update Hi everyone - Thank you for your continued interest and participation in the Lighting Ordinance Update effort. The Lighting Ordinance Update item is scheduled for the upcoming City Council Hearing on November 10, 2025. Please review the staff report and associated attachment from the City Council Meeting Agenda page here. The Lighting Ordinance Update is Item #8 on the agenda. Please review the PUBLIC COMMENTS section of the agenda to find out how to send your written comments in advance of the meeting, and how to participate and provide your comments orally in- person and virtually. As always, if you have any questions or problem accessing the staff report and associated attachments for the Lighting Ordinance Update item, please do not hesitate to contact me. Thanks again for your continued interest and participation in this effort, Kelly Cha (she/her) Senior Planner Planning and Development Services (650) 329-2155 | Kelly.Cha@PaloAlto.gov www.PaloAlto.gov 1 of 1 November 4, 2025 Palo Alto City Council City of Palo Alto 250 Hamilton Avenue Palo Alto, CA 94301 Re: City Council Consideration of Lighting Ordinance VIA EMAIL kelly.cha@cityofpaloalto.org Dear Mayor Lauing and Members of the City Council, We would like to extend our sincere thanks to the City Council for the opportunity to provide feedback on the proposed changes to the Lighting Ordinance. As the landowner of Stanford Research Park, we are concerned that the proposed Lighting Ordinance poses substantial design and implementation challenges for both the University and our tenants in the Research Park area. We attended the October webinar outreach meeting that was organized by the Chamber and City staff to engage with business owners. We echo many of the concerns shared by fellow owners and tenants during the discussion. Based on our preliminary review, we believe that it may not be feasible to comply with the proposed standards while also maintaining the safety, security, and regulatory compliance that are essential to our operations and responsibilities as a property owner. Safety Considerations: Outdoor lighting in the Research Park is intentionally designed to provide consistent and adequate coverage based on fixture type, bulb strength, and layout. Requiring changes such as adding motion sensors, shrouds, or altering fixtures and bulbs would lead to poor and unsafe lighting conditions. Motion-activated lighting does not provide a sense of safety or security, especially in a complex where tenants do not have fixed closing hours. Maintenance, janitorial, and security staff are often on-site after midnight, and researchers and engineers regularly work late as deadlines approach. This could also apply to future tenants. A low-lit campus, particularly with motion sensors, would feel unsafe and unwelcoming at night. This is also concerning as it relates to parking garages, where consistent lighting is essential for visibility and security. We urge the City to reconsider these proposed requirements and allow more flexibility for multi-tenant office sites. Implementation Costs: The commercial office market is already under significant stress, and the proposed lighting standards would place an added burden on property owners. Upgrading lighting can be costly and may require extensive parking lot redesign, including relocating light poles and trenching to modify concrete, asphalt, trees, utilities, and drainage systems. We urge the Council to consider the financial and practical impacts on property owners and explore more flexible approaches to implementation. Policy Standards and Regulatory Alignment: Retrofitting existing lighting fixtures for Dark Sky compliance requires a qualified lighting designer to ensure all specifications are properly met. This process includes conducting photometric studies to achieve correct lighting levels, ensuring JA8 and Title 24 compliance, meeting ADA requirements, and incorporating a 3000 Kelvin LED light source for improved visual acuity. To provide more detail: a light source with a color temperature of 2700 Kelvin, while ideal for indoor settings, appears too yellow for nighttime outdoor environments. This warmer tone can reduce visual acuity and is not suitable for an outdoor environment that is based on a bluer light. Conversely, color temperatures above 3000 Kelvin tend to appear too blue. A 3000 Kelvin light, which produces a neutral white tone, is considered optimal according to studies. Considering this, Stanford respectfully requests that the maximum allowable standard be adjusted to 3000 Kelvin. This adjustment would also ensure greater product availability and flexibility in meeting the ordinance. We are also concerned about potential conflicts with California Title 24 and Cal/OSHA lighting requirements. These state and federal standards may supersede local regulations, rendering parts of the proposed ordinance unenforceable. We urge the City to carefully evaluate these overlaps to avoid legal and practical inconsistencies. Finally, the current proposal would require all properties to come into full compliance within five years of the ordinance’s effective date. This timeline may place an undue burden on property owners, particularly given the costs and logistical complexity involved. We request that the City exempt existing buildings and apply the new standards only to new construction projects. We want to encourage the City to keep Palo Alto attractive to business and appreciate the City Council’s thoughtful consideration of our comments. Please reach out to our team with any questions. We appreciate your consideration, and please let me know if you have further questions at tgriego@stanford.edu Sincerely, Tiffany Griego Senior Managing Director, Commercial Real Estate Stanford Real Estate, Stanford University tgriego@stanford.edu cc: Jonathan Lait, Director of Planning and Development Services Jennifer Armer, Assistant Director, Planning and Development Services Coleman Frick, Long-Range Planning Manager, Planning and Development Services Kelly Cha, Senior Planner, Planning and Development Services Lighting Ordinance Update City Council Kelly Cha, Senior Planner November 10, 2025 www.PaloAlto.gov 2 Purpose •Council Priority: Climate Change & Natural Environment “Initiate an evaluation of strategies to protect natural habitats such as bird safe glass and wildlife protection from light pollution.” •Consistent with Dark Sky principles, which is an effort to turn back the sky to its natural dark sky to the extent feasible by reducing light pollution. 3 Dark Sky Lighting Principles USEFUL Use light only if it is needed TARGETED Direct light so it falls only where it is needed LOW LEVEL L ight should be no brighter than necessary CONTROLLED Use light only when it is needed WARM -COLORED Use warmer color lights where possible © 2025 DarkSky International 4 City Council Direction from April 2025 •Existing Lighting Compliance Requirements: •Include different deadlines for residential and nonresidential properties •Add exceptions for undue financial burden and special security concerns. •Modifications to regulations including: •Apply to replacement of existing outdoor lighting fixtures, or changing the lighting type or system. •Reduce maximum light spillage to 0.1 foot candle. •Extend lighting curfew to midnight, including holiday lighting. •Increased efforts to raise awareness to support compliance. 4 Areas of Special Security Concerns •City Council requested for an exception for special security concerned areas. •Staff recommends adding an exemption for the Edgewood neighborhood instead: •Neighborhood’s unique characteristics, including close proximity to a creek and bordering another jurisdiction. •No particularly high crime areas designated in the City. 8 Additional Engagement Comments received through focused outreach meeting with Palo Alto businesses: •Concerns over existing lighting compliance. •Council direction from April 2025 •Safety and security concerns with the new requirements, especially for businesses with overnight or non-standard hours of operation. •Lighting curfew "at midnight, 2 hours after close of business, or when people are no longer present in exterior areas, whichever is later." •Federal Occupational Safety and Health Administration (OSHA) workplace regulations. •Lighting curfew exception on "building entrances, parking areas, walkways, and driveway areas." •Conflict precedence provision on state or federal laws. 4 Minor Modification Section 18.40.250(d)(7): Single family residential sites adjacent to San Francisquito Creek and fronting on Edgewood Drive if the portion of the site subject to a permanent easement in favor of the Santa Clara Valley Water District (or its successor in interest) for flood control purposes is reconfigured after January 1, 2002. These sites shall be subject to the requirements under Section 18.40.250(e)(4)(A). 12 Next Steps •Adoption of the ordinance •Second reading (consent item) required for ordinances •Effective on the 31st day of the second reading •Community resources •Project webpage update (www.PaloAlto.org/OutdoorLighting) •Educational materials to increase awareness to support compliance KELLY CHA Senior Planner Kelly.Cha@PaloAlto.gov (650) 329-2155 Lighting Ordinance Update PaloAlto.Gov/OutdoorLighting