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Home My WebLink AboutStaff Report 2511-5569CITY OF PALO ALTO CITY COUNCIL Monday, December 08, 2025 Council Chambers & Hybrid 5:30 PM Agenda Item 15.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) Staff Presentation, Public Comment City Council Staff Report From: City Manager Report Type: ACTION ITEMS Lead Department: Planning and Development Services Meeting Date: December 8, 2025 Report #:2511-5569 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 Note: This report has been updated from its initial November 10, 2025, publication to incorporate a recent ordinance change that expressly exempts select public facilities, as discussed in the analysis section. 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. 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 3. Low Level: Light should be no brighter than necessary. Use the lowest light level required. Be mindful of surface conditions, as some surfaces may reflect more light into the night sky than intended. 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. 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 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: 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 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 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 of plan review and introduce additional regulatory steps to the permitting process, and is therefore not recommended. POLICY IMPLICATIONS doesn't change density, layout, or height. Minor cost or design modifications may be needed for compliance, but dark sky products and lighting technologies are available. FISCAL/RESOURCE IMPACT STAKEHOLDER ENGAGEMENT proposed Lighting ordinance update due to its overly restrictive nature, negative impact on safety, and lack of sufficient community input. 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 reduction in light pollution so that the sky returns or becomes closer to its natural nighttime darkness. B. Adhering to Dark Sky principles, which promote responsible outdoor lighting practices, can signiﬁcantly reduce light pollution and mitigate its harmful eﬀects. These principles emphasize using light only if it is needed, directing so that it falls only where it is needed, having lighting 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 priorities, one of which is the Climate Change & Natural Environment – Protection & Adaptation, and included an objective to “approve a bird safe glass and wildlife light pollution protections 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 regulations and draft ordinance. E. On August 14, 2024, the Planning and Transportation Commission reviewed the draft ordinance, provided feedback and recommended that staﬀ return with more information, continuing the hearing to a date uncertain. F. On October 30, 2024, the Planning and Transportation Commission recommended that City Council adopt the ordinance. G. The ordinance aligns with Dark Sky principles and is intended to reduce light pollution at night, protecting wildlife and supporting a sustainable and resilient community. / / / / / / *** NOT YET APPROVED *** 2 0160151_20250821_ay16 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: (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. *** NOT YET APPROVED *** 3 0160151_20250821_ay16 (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 lighting” means lighting installed and operated in connection with holidays or traditions within the time period speciﬁed in Section 18.40.250(d)(4). String lighting used outside these periods is not considered seasonal lighting and shall be subject to requirements in Section 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 *** NOT YET APPROVED *** 4 0160151_20250821_ay16 (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). (8) Lighting for streets, roadways, and public walkways and bikeways. (9) Lighting for Public Facilities Operations. Nothing in this section shall be interpreted to restrict, limit, or otherwise regulate lighting that, in the reasonable judgment of the City Manager, is prudent or necessary for operations or safety of public facilities that operate on a 24 hours per day, 7 days a week basis. (e) Lighting Standards. (1) Shielding (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 lighting 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. / / / / *** NOT YET APPROVED *** 5 0160151_20250821_ay16 (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. (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. *** NOT YET APPROVED *** 6 0160151_20250821_ay16 (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. (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, rooftop gardens, rooftop 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. *** NOT YET APPROVED *** 7 0160151_20250821_ay16 (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, 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. Unless exempt under Section 18.40.250(d), 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. *** NOT YET APPROVED *** 8 0160151_20250821_ay16 (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. 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, *** NOT YET APPROVED *** 9 0160151_20250821_ay16 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. 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. / / / / / / / / / / *** NOT YET APPROVED *** 10 0160151_20250821_ay16 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 Lighting Ordinance Update City Council Kelly Cha, Senior Planner December 8, 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. 5 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. 6 Additional Engagement Comments received through focused outreach meeting with Palo Alto businesses: Concerns regarding retrofitting existing lighting to comply with ordinance. •Policy consideration for Council – in April 2025, direction provided to staff to require phased compliance. •Sierra Club has recently modified their view on this provision. 6 Additional Engagement (continued) Comments received through focused outreach meeting with Palo Alto businesses: Concerns over employee safety and compliance with Federal Occupational Safety and Health Administration (OSHA) workplace regulations. •Lighting curfew "at midnight, 2 hours after close of business, or when people are no longer present in exterior areas, whichever is later." •Exceptions for Lighting Control section already address their concern: •18.40.250(e)(4)(D) Exceptions for Lighting Control. "(i) Any lighting at building entrances, parking areas, walkways, and driveways area" (applies to residential and commercial properties) •Conflict precedence provision on State or Federal laws. 7 Modification – Exemptions (18.40.250(d)) (d) Exemptions. (1) Full Exemptions. The following are fully exempt: (A) Lighting for emergency personnel; (B) Lighting authorized by a special event permit, special or temporary use permit, or construction permit; (C) 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; (D) Lighting for streets, roadways, and public walkways and bikeways. (E) Lighting for Public Facilities Operations. Nothing in this section shall be interpreted to restrict, limit, or otherwise regulate lighting that, in the reasonable judgment of the City Manager, is prudent or necessary for operations or safety of public facilities that operate on a 24 hours per day, 7 days a week basis. [Note: Items (D) and (E) are already incorporated into the draft ordinance] 8 Minor Modification – Exemptions (18.40.250(d)) Continued... (2) Conditional Exemptions. The following are exempt subject to specific conditions: (A) Illuminated street numbers, subject to Section 18.40.250(g). (B) Seasonal lighting during the period of October 15 through January 15 of each year, subject to extinguishment at 12:00 a.m. (C) 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, subject to Sections 18.40.250(g) and Section 18.40.250(e)(4)(A). (D) Lighting for Emergency Shelters. Lighting for emergency shelters , shall be subject to PAMC 18.14.060. 9 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 From:Melissa Borgesi To:Council, City Cc:Jane Mark; Ana Ruiz; Susanna Chan Subject:12/8/25 City Council Meeting Agenda ITEM 15: REINTRODUCED FIRST READING: Adoption of an Ordinance Updating Palo Alto Municipal Code Section 18.40.250 (Lighting) Date:Monday, December 8, 2025 10:46:40 AM Attachments:image001.png Midpen Ltr_Palo Alto Lighting Ordinance 20251208.pdf CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. i Dear City Council Members and Staff, Please find attached our agency’s comments regarding the draft ordinance updating the 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, which will be discussed at this evening’s City Council meeting. Thank you for the opportunity to comment on this proposed ordinance language. Sincerely, Melissa Melissa Borgesi Planner III Midpeninsula Regional Open Space District 5050 El Camino Real, Los Altos, CA 94022 (650) 625-6531 Direct openspace.org This message needs your attention This is their first mail to some recipients. Mark Safe Report Powered by Mimecast December 8, 2025    City of Palo Alto City Council City Hall 250 Hamilton Avenue  Palo Alto, CA 94301    SENT VIA E-MAIL TO: city.council@CityofPaloAlto.org    Subject: 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 Dear Palo Alto City Council,  On behalf of the Midpeninsula Regional Open Space District (Midpen), we respectfully submit the following comments regarding the revised lighting ordinance. Comprised of over 70,000 acres of acquired and protected open space on the San Francisco Peninsula, Midpen is one of the largest regional open space districts in California. Our mission is to acquire and preserve a regional greenbelt of open space land in perpetuity, protect and restore the natural environment, and provide opportunities for ecologically sensitive public enjoyment and education.  Within the City of Palo Alto’s jurisdiction, Midpen owns and manages Monte Bello Open Space Preserve (Preserve). Midpen appreciates the City of Palo Alto utilizing “dark sky” principles in developing the lighting ordinance update, particularly in the areas that serve as wildlife refuge sites including creek and riparian corridors, large open spaces, and the Baylands. The clear guidance for light direction, intensity and color in the current ordinance draft will assist with protecting these sensitive resource areas. Midpen supports approval of such an ordinance with consideration for any suggested revisions to improve the ordinance from a perspective of ecological value and benefit. We recognize that the City will rely on a community-based approach for compliance and commend the City’s efforts with developing educational and outreach materials to communicate the importance of protecting a “dark sky” and complying with wildlife light pollution protections standards. Thank you for the opportunity to comment on this ordinance revision. Should you have any questions about this letter, please contact me at (650) 625-6563 or via email at jmark@openspace.org. Sincerely,       Jane F. Mark, AICP   Planning Manager    CC: Ana Ruiz, General Manager   Susanna Chan, Assistant General Manager   From:promiserani To:Council, City Subject:Support of Dark skies and induction cooking Date:Sunday, December 7, 2025 9:04:54 PM CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. i Hi, I am writing in support of the Dark skies ordinance in Palo Alto, and in support of induction cooking as well. Dark skies are important for our quality of life, and for the health of our wildlife and children in our areas. In addition to saving energy with lower lighting, the efforts will reduce greenhouse gases, allowing better scientific observation of the night sky, the darker skies will allow for better navigation of birds, health of nocturnal animals, effects on plants, and improve sleep for humans of all ages. Induction cooking is also important for Palo Alto to reach climate goals, improve indoor air quality, and reduce fossil fuel use, not to mention reduce overall energy use. The move toward total electrification will require this switch, and rebates and requirements will help hasten these positive changes. Please vote in favor of both of these efforts for all Palo Altans. Prerana Jayakumar Midtown This message needs your attention This is a personal email address. Mark Safe Report Powered by Mimecast From:Tom Fountain To:Council, City; Lauing, Ed; Cha, Kelly Subject:Proposed Outdoor Lighting Ordinance Date:Sunday, December 7, 2025 8:47:51 PM 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, 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 health and safety of residents must take priority. The exemption for Edgewood properties contains a drafting error and, consistent with Staff's recommendation, 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. Most notably, the proposed ordinance should not require retrofit to existing residences. It is telling when even the proposal's advocates -- including the Sierra Club and the American Bird Conservancy -- believe this proposed ordinance goes too far. The cost and environmental waste produced by this poorly considered ordinance more than offsets the stated environmental benefits. Additionally, 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. Based on the opposition from Stanford University, Stanford hospital, and the many businesses who participated in the workshop, it is clear the cost is similarly high for commercial enterprises. We should find solutions to reduce housing costs and promote local businesses, not drive up cost by requiring retrofit construction. Finally, there are many problematic issues with this proposed ordinance and its retrofit Alto homeowner selling their 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 applied to existing residence; it is disheartening that after months, staff has still not addressed even a single shortcoming. For example, dimming is not a permitted solution to make an existing fixture and luminaire comply. 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 construction and not retroactively applied to existing residences. If existing properties must be covered, then limits should be expressed in lux rather than lumen. The current proposed ordinance due to the retrofit requirement 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 respectfully encourage City Council to send the ordinance back to Staff to better address these issues. Sincerely, Tom Fountain Palo Alto resident From:Kristin Sato To:Council, City; Lauing, Ed; Cha, Kelly Subject:Proposed Outdoor Lighting Ordinance Date:Sunday, December 7, 2025 6:26:14 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 in support of the Edgewood Neighborhood Alliance and the following: I fully 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).” Last, I oppose this lighting ordinance be applied retroactively. If this lighting ordinance must be passed, it should only apply to new construction. Thank you. Sincerely, Kristin Sato This message needs your attention This is a personal email address. Mark Safe Report Powered by Mimecast From:herb To:Council, City; Clerk, City Subject:December 8, 2025 City Council Meeting, Agenda Item #15: Outdoor Lighting Restrictions Date:Sunday, December 7, 2025 3:06:54 PM CAUTION: This email originated from outside of the organization. Be cautious of openingattachments and clicking on links. DECEMBER 8, 2025 CITY COUNCIL MEETING AGENDA ITEM #15: OUTDOOR LIGHTING RESTRICTIONS The public letters in this meeting's agenda packet for this agenda iteminclude only those public letters that were included in the agendapacket for the November 10, 2025 meeting, but omit letters receivedafter that agenda packet was distributed. Reproduced below is the letter I sent you for the November 10, 2025meeting regarding light pollution from unshielded LED street lights. Packet Page 300 of the current agenda packet shows the effect thatshielding LED street lights has on decreasing light pollution. An example of the light pollution from unshielded LED street lights canbe seen from the LED street light in front of the Children's Library onHarriet Street that is at the end of the library that is furthest fromHopkins Avenue and lights up the intersection of Harriet Street andHopkins Avenue. Residences across the street from the Children's Library are closer tothe unshielded light than the distance from that light to HopkinsAvenue. I wonder if anyone who lives across the street from that LEDstreet light is bothered by its unshielded light. Thank you for your consideration of these comments. Herb Borock 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 be shields 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:Pria Graves To:Council, City Subject:Lighting Ordinance Update Date:Sunday, December 7, 2025 12:04:11 PM CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links. Dear Council Members, I am writing to encourage you to support the proposed update to the lighting ordinance to be consistent with the Dark Sky principles. Humans and all other animals do better when not subjected to bright lighting at night. Migrating birds and nocturnal wildlife are especially vulnerable. A darker night sky would also allow us to once again enjoy a view of the stars! In addition to lighting around homes, it would be extremely helpful if we could “fix” the athletic facility lighting! The field at Page Mill and El Camino sends light to my home several blocks away. And the lighting of sports fields on the Stanford Campus makes driving toward El Camino difficult at night. The light “poles” also ruin the view of the Hoover Tower even in the day time! Horrific. I’ve lived here for 40 years and each year our surroundings, street lights and other sources, get brighter and brighter. Thank you for your support. Regards, Pria Graves 2130 Yale Street From:Jennifer Landesmann To:Council, City Subject:Night time ordinance Date:Saturday, December 6, 2025 4:28:44 PM CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. Dear Council, The City's staff report for Monday has a recommendation to "adopt new outdoor lighting regulations..in order to increase the health and well-being of Palo Alto residents, protect wildlife and natural ecosystems, and reduce light pollution." Conservation of energy and beautifying the night sky are listed among the advantages of the ordinance. And some key health issues: the body’s natural circadian rhythm, promoting better sleep improving safety and comfort at night. Research about negative impacts on people, species, and the natural environment in fact are about the importance of the timeframe (night time). I would suggest that the City begin to consider a broader approach where various initiatives fit with respect to nighttime protection. Certainly the cumulative effects of noise and light pollution are an issue. Here is a scary thought - Unignorable Flying Billboards at 250 feet. I support that the City give "nighttime" the importance that it should have for the promotion of the health of humans and the natural environment. To abate the various types of pollution during this timeframe - and in a world that has become 24/7. Jennifer From:Ailsa Ludvik To:Council, City Subject:December 8, 2025 Agenda item 8: please STOP this terrible idea....say NO Date:Saturday, December 6, 2025 4:15:03 PM CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. i To the Palo Alto City Council Please vote NO on this notion of 'dark skies'. Lights at night are NOT light pollution, lights at night time are a miracle and keep people safe. Please concentrate on things that will improve living in Palo alto, and stop encroaching into our lives with scary notions of dying from night time lights ! Fix University Ave, it's dismel and dirty....repair the roads....trim the City trees.....leave our night lights alone. thank you Ailsa Ludvik Palo Alto This message needs your attention This is a personal email address. This is their first email to you. Mark Safe Report From:kip husty To:Council, City Subject:Dark Sky Ordinance Date:Friday, December 5, 2025 10:40:51 PM CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. i Dear Council Members, My wife, Anne, and I have lived in the Seale Park neighborhood for over 25 years, and have lived in Palo Alto for nearly 50 years (three years in the Woodland neighborhood). Both of us, as well as our daughter, coveted the rare dark skies that we could find could find in empty lots (a thing of the past) and parks. The street lighting was too obtrusive for us, barring any aesthetically pleasing sense of dark skies with stars. The conditions for dark skies has gotten worse over the years, and now my neighborhood park, Seale Park, has installed a noticeably more offensive light (I believe it is an LED light). The field where we could go on walks and stand gazing into darkness now has a light so bright at one end that shadows are cast over 50 yards away! The santuary of darkness that we once enjoyed has been destroyed. Coupled with the obnoxious brightness of a bulb that irritates the eyes as they dilate in the semi-dark, we have not heard the night 'birds' that I used to hear and see flying over the field (I don't know what they were, they might have even been bats) when a sodium vapor light was in this spot. It was bad, but it was far more confined. We understand the fear of the dark, but it is not very rational. We have seen people in the park two or three times in thousands of late night walks to the field (when we were younger, it was a near nightly activity, now it is mostly me by myself. Crime is a problem, but late night break-ins are a small share of the crime. While violence is a potential, it is not a rampant crime in this city; we feared skunks much more than an assault. Additionally, we all should note that so-called 'white-collar' has a far greater cost to society than burglary, yet fighting 'white-collar' crime occupies tiny fractions of the law enforcement time and resources, and does not place environmental and beauty destroying measures. Further, economic inequality far and away over-shadows darkness as a precursor to crime. We do not expect Palo Alto government to prioritize rooting out these latter ills that are more relevant to the problem of crime than lighting the skies, but we do expect the city to protect the quality of life and the natural environment that has made Palo Alto such a desirable community to call home. This message needs your attention This is a personal email address. Mark Safe Report Powered by Mimecast Please, support and pass the Dark Sky (Outdoor Lighting) Ordinance and give us back the night. Anne and I do not fear the dark, we do, however, find fault with a city that blindly throws ugly and damaging solutions having little to no significant function other than to placate ungrounded and exaggerated fears. Thank you, Kip and Anne Husty 922 Bautista Ct. Palo Alto, CA, 94303 From:Jeff Levinsky To:Council, City Subject:Monday"s Agenda Item 15: Please Vote for a Strong Dark Sky Ordinance Date:Friday, December 5, 2025 6:06:04 PM CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. Dear City Council members: I agree with the Sierra Club and Bird Alliance that we need to strengthen our dark sky ordinance. Having worked and lived in Palo Alto for many decades, I’ve seen much energy spent to improve our town for human beings. Let’s also consider how we impact other species. There are easy steps we can take to protect birds, such as: · Require nonessential outdoor lighting be off by 11 PM, rather than midnight · Have new buildings, remodels, and fixture replacements meet compliant lighting standards · Prohibit blinking/flashing/rotating lights, searchlights, aerial lasers, and spotlights citywide · Insist that existing adjustable lighting comply within one year of the ordinance going into effect None of these are onerous. Please consider that as neighboring cities pass such laws, we need to as well to create a region-wide nightly dark area that’s better for birds and our environment. We always want to be the bright spot, but in this case we should go dark. Thank you, Jeff Levinsky From:Pat Markevitch To:Council, City Subject:Outdoor Lighting Ordinance Agenda Item 15 Date:Friday, December 5, 2025 5:49:42 PM CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links. Honorable City Council members, I am in favor of the proposed out5door lighting ordinance. I served the Parks and Recreation Commission for over 10 years so I am very aware of the dangers to birds when it comes to artificial light. My personal experience with overly bright artificial light is ongoing. The apartment building behind me, on the corner of Hawthorne and Ramona underwent a renovation. As a result, the back area of the complex has these lights that are so bright that if you were to look at them for more than a second, your eyes will become physically pained. It's like looking at the Sun. I need fresh air to sleep so my shades need to be pulled up. As a result, the lights from their yard literally spotlights my bed so I have to build a pillow wall to keep the lights from shining in my eyes. I have no idea who to contact. All they need to do is lower the brightness, aim the lights down into the yard and put the lights on motion detectors. Thank you Pat Markevitch From:Melanie Grondel To:Council, City Subject:Dark Sky !! Date:Friday, December 5, 2025 2:34:17 PM CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. i Dear Council Members, The migrating birds have been a great concern for many years. They are encountering significant and increasing risks on their migration routes in particular at night when they need a dark sky for their migration navigation . The birds are an essential part of our eco system and provide joy for our spirit as they are the most frequent wildlife that we encounter in the city. We value our trees, we protect our wetlands, it is high time that we protect the birds. They are in serious decline ! 29% of migrating birds are gone and one third of the birds are under conservation concern in the US and Canada (Cornell Labs) . Our trees and parks and gardens are unthinkable without birds . They are our friends and need protection now ! I am ready to take some extra care and apply the Dark Sky Ordinance to my environment and I hope that my fellow Palo Altans are ready to do the same. Let’s protect the birds like we protect our trees. I am asking the City Council to fully support the Dark Sky Ordinance. Thank you for your consideration. Melanie Grondel - College Terrace. This message needs your attention This is a personal email address. This is their first email to you. Mark Safe Report From:Meri Gruber To:Council, City Subject:Opposition to Proposed Dark Sky Ordinance - Agenda Item 15 Date:Friday, December 5, 2025 11:05:54 AM CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. Dear City Council Members, I urge you to reject the proposed outdoor lighting ordinance for the following reasons: Safety First: Well-lit streets reduce pedestrian fatalities by 30-50%. The mandatory midnight curfew creates genuine safety risks for residents returning home late, taking out trash, or responding to emergencies. There is an exemption for Edgewood Drive based on security perceptions. If security lighting matters there, it matters everywhere. Unenforceable Law: Staff explicitly states the city "does not have sufficient resources to proactively enforce the ordinance." Creating laws that cannot be enforced breeds selective enforcement and neighbor disputes. Disproportionate Costs: Requiring all existing lighting to comply imposes enormous costs on homeowners and businesses. No cost-benefit analysis justifies this burden. Missing Evidence: The ordinance provides no baseline data on current light pollution levels, no quantified wildlife harm, and no comparison of less restrictive alternatives. Good environmental policy balances goals with practicality. This ordinance sacrifices safety, imposes massive costs, and creates laws the city cannot enforce—all without demonstrated local necessity. Please vote no. Thank you for your service to our community. Best regards, Meri Gruber Palo Alto From:Catherine Cohen To:Council, City Subject:December 8, 2025 Agenda item 8: i strongly oppose a strong outdoor lighting ordinance Date:Friday, December 5, 2025 10:51:53 AM CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links. Hi, my name is Catherine Cohen. I have been born and raised in Palo Alto. I am strongly against the outdoor lighting ordinance that you are proposing. I have dogs and do not have a yard and often have to take them out in the middle of the night. I only feel safe because of the lights that guide my way in the darkness. I also fear that even with the coyote issues we’re having now that will intensify with less light and also cause a safety concern. I also feel that having less lights is just opening the door for more crime in Palo Alto. Something we’re already struggling with. Car break-ins. House break-ins. I believe we could solve the light issue by maybe asking residence to install lights that point down versus pointing out or up but going into a darkness is not an option in my opinion. Thank you Sent from my iPhone Please excuse typos From:Jo Ann Mandinach To:Council, City Subject:Subject: 12/8/25 Agenda Item 15: We need a strong outdoor lighting ordinance Date:Friday, December 5, 2025 8:57:22 AM CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. Dear Mayor & City Council, Please adopt the Dark Sky (Outdoor Lighting) Ordinance and instruct the city to everything possible to publicize this. Why do I care? Because two separate properties directly behind me were sold this past year and both new owners have extremely bright lights shining into their backyards -- AND into mine -- all night. One has a particularly bright and glaring spotlight that's aimed high enough to be extremely annoying. As more and more of us trim trees and bushes due to fire insurance requirements, these extremely bright lights become more problematic. Thanks for your consideration. Jo Ann Mandinach Palo Alto, CA 94301 From:GreenSpacesMV To:Council, City Subject:Support for a Strong Palo Alto Dark Sky Ordinance (Agenda Item 15 on 12/8 Agenda) Date:Friday, December 5, 2025 8:21:41 AM Attachments:GSMV letter to PA - Dark Sky.pdf CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. i Hello, Please see the attached comment letter in support of a Strong Dark Sky Ordinance in Palo Alto. Thank you for your time, Silja Paymer GreenSpacesMV This message needs your attention This is a personal email address. This is their first email to your company. Mark Safe Report December 5rd, 2025 Re: Support for a Strong Palo Alto Dark Sky Ordinance (Agenda Item 15 on 12/8 Agenda) Dear Mayor Lauing and Palo Alto Councilmembers, GreenSpacesMV is a volunteer-based community group advocating for parks, trees, biodiversity, climate resilience, and nature-forward planning in Mountain View. Our members have been deeply engaged in advancing responsible lighting practices in our own city, including early outreach and policy recommendations that helped initiate Mountain View’s upcoming citywide Dark Sky Ordinance process. As neighbors who share the night sky, and are impacted by light that crosses city borders, we strongly support the recommendations submitted by the Sierra Club Loma Prieta Chapter and the Santa Clara Valley Bird Alliance. In particular, we urge Palo Alto to: ● Require all nonessential outdoor lighting to be turned off by 11:00 PM with reasonable exceptions, rather than midnight. ● Require all new buildings, remodels, and fixture replacements to meet compliant lighting standards. ● Apply the prohibition on blinking, flashing, rotating lights, as well as searchlights, aerial lasers, and spotlights, citywide, including Edgewood. ● Require existing adjustable lighting to be compliant within one year of the effective date of the ordinance. Mountain View has recently launched community engagement for our own Dark Sky Ordinance, with public updates and materials available at MountainView.gov/DarkSky. As neighboring cities working toward regional ecological and climate resilience we hope Palo Alto will adopt a strong ordinance that sets an example for other jurisdictions in the Midpeninsula. Thank you for your leadership in reducing light pollution and protecting our shared night sky. Sincerely, Silja Paymer for GreenSpacesMV From:Lauren Swezey To:Council, City Subject:In favor of Outdoor Lighting Ordinance Date:Thursday, December 4, 2025 10:14:41 PM CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. i Dear Council Members, My name is Lauren Bonar Swezey. I am a lifelong resident of Palo Alto and have lived near the San Francisquito Creek for many years. I’ve always considered Palo Alto a special place, especially because of its lush tree canopy and the endemic and migratory birds that visit the trees and gardens here. Birds are constantly at risk in a city environment due to outdoor lighting. It disorients them and disrupts migration. When I worked at Facebook/Meta on the Frank Gehry-designed buildings, we installed bird-friendly windows and directed all lighting to face downward. We also dimmed lights at night and adhered to Lights Out Campaigns during migration periods. The Palo Alto City Council must protect these special visitors by passing the outdoor lighting ordinance. Thank you for your support, Lauren Bonar Swezey This message needs your attention This is a personal email address. This is their first email to you. Mark Safe Report From:Dashiell Leeds To:Council, City; Burt, Patrick; Lauing, Ed; Lu, George; Lythcott-Haims, Julie; Reckdahl, Keith; Stone, Greer; Veenker, Vicki Cc:advocate@scvbirdalliance.org; Clerk, City; Cha, Kelly; James Eggers; Mike Ferreira; Gita Dev; Barbara Muir; Wils Cain Subject:SCLP and SCVBA re December 8 Agenda Item 15 - Dark Sky (Outdoor Lighting) Ordinance Date:Thursday, December 4, 2025 6:58:22 PM Attachments:SCLP SCVBA Letter to Palo Alto re Dec 8 Dark Sky Ordinance.pdf SCLP SCVBA Redlined Version of Palo Alto Draft 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, 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 five requests listed in the attached letter. We have also attached a redlined version of the ordinance showing our suggested changes. 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 December 4, 2025 Palo Alto City Council 250 Hamilton Ave Palo Alto, CA 94301 Re: December 8 Agenda Item 15 - 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 five requests. We have made changes in blue since our November 10th letter to the City Council on this subject. ● Amend Sections 18.40.250(d)(4) and 18.40.250(e)(4)(A) to adjust the curfew start time from 12 a.m. to 11 p.m. ● 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) and (3), 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 Sections 18.40.250(d)(4) and 18.40.250(e)(4)(A) to adjust the curfew start time from 12 a.m. to 11 p.m Current text Section 18.40.250(d) Exemptions. The following types of lighting are exempt from the lighting requirements of the section: (4) Seasonal lighting, subject to extinguishment at 12:00 a.m., during the period of October 15 through January 15 of each year; Section 18.40.250(e) Lighting Standards. (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. Proposed Text Section 18.40.250(d) Exemptions. The following types of lighting are exempt from the lighting requirements of the section: (4) Seasonal lighting, subject to extinguishment at 11:00 p.m. 12:00 a.m., during the period of October 15 through January 15 of each year; Section 18.40.250(e) Lighting Standards. (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 11:00 p.m. 12:00 a.m., two hours after the close of business, or when people are no longer present in exterior areas, whichever is later. Justification The Lighting Curfew standards in this ordinance are incredibly flexible, allowing for lights to remain on two hours after the close of business or when people are no longer present in exterior areas, whichever is later. Adjusting the start time of the curfew will not affect luminaires that remain illuminated at late hours for those reasons. Adjusting the curfew start time one hour earlier, to 11:00 p.m. will allow the ordinance to maximize its light pollution reduction at key nighttime hours while retaining the flexibility to allow residents and businesses to operate normally. Furthermore, the 11:00 p.m. time would correspond with the curfews of many other adopted ordinances, such as those in Cupertino, Malibu, and Los Altos, which all use 11pm residential curfews. Brisbane and Rancho Palos Verdes contain curfews which, at the latest, begin at 10 p.m. Request #2 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 #3 Amend Section 18.40.250(d)(7) to ensure that prohibited lighting types are not allowed in the exempted Edgewood Drive properties. 1 https://cityofpaloalto.primegov.com/Public/CompiledDocument?meetingTemplateId=16025&compileOutpu tType=1 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 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 #4 Remove 18.40.250(L)(2)(A)(B) and (3), removing retrofit requirements 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. (3) Any nonconforming lighting still in place after the compliance deadline shall remain extinguished at all times until they are brought into compliance. 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) and (3), 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. (3) Any nonconforming lighting still in place after the compliance deadline shall remain extinguished at all times until they are brought into compliance. Justification Requiring retrofits for all existing lighting could 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 #5 Retain and shorten the compliance period in Section 18.40.250(L)(1) for easily adjustable existing lighting fixtures to one year 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 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.” 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 Note from SCLP and SCVBA: The text we recommend removing will be colored red and struck through, and the text we recommend adding will be colored blue. All other non-colored strikethroughs are those originally proposed by staff. 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 reduction in light pollution so that the sky returns or becomes closer to its natural nighƫme darkness. B. Adhering to Dark Sky principles, which promote responsible outdoor lighting practices, can significantly reduce light pollution and mitigate its harmful effects. These principles emphasize using light only if it is needed, directing so that it falls only where it is needed, having lighting 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 priorities, one of which is the Climate Change & Natural Environment – Protection & Adaptation, and included an objective to “approve a bird safe glass and wildlife light pollution protections 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 regulations and draft ordinance. E. On August 14, 2024, the Planning and Transportation Commission reviewed the draft ordinance, provided feedback and recommended that staff return with more information, continuing the hearing to a date uncertain. F. On October 30, 2024, the Planning and Transportation Commission recommended that City Council adopt the ordinance. G. The ordinance aligns with Dark Sky principles and is intended to reduce light pollution at night, protecting wildlife and supporting 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: (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 lighting” means lighting installed and operated in connection with holidays or traditions within the time period specified in Section 18.40.250(d)(4). String lighting used outside these periods is not considered seasonal lighting and shall be subject to requirements in Section 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 11:00 p.m. 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) and 18.40.250(g). (e) Lighting Standards. (1) Shielding (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 lighting 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 11:00 p.m. 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. (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, NVR1, 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. (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 footcandle 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, rooftop gardens, rooftop 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, 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 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 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. 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. 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. 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: 12/8/25 City Council Hearing on the Lighting Ordinance Update Date:Thursday, December 4, 2025 4:46:41 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 private lessees and tenants in Stanford Research Park. We are resending our initial letter because it was not included in the packet distributed to you in advance of the 12/8/25 hearing. 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 From:Alexandra Mendoza To:Council, City Subject:City Council Meeting, December 8th: Agenda Item 15. Dark Skies Ordinance Date:Wednesday, December 3, 2025 5:37:27 PM Attachments:Agenda Item. 15 Dark Sky Ordinance.pdf CAUTION: This email originated from outside of the organization. Be cautious of opening attachmentsand clicking on links. i Hello, Attached is Green Foothills written comment for City Council's Agenda Item. 15 on December 8th. Thank you! Lexi Mendoza photo Alexandra Mendoza (She/Her) Environmental Associate Green Foothills | (650) 968-7243 | greenfoothills.org Double your donation by 12/31 thanks to a 2X matching grant. Donate today. This message needs your attention This is their first email to you. Mark Safe Report 1 December 3, 2025 Palo Alto City Council 250 Hamilton Ave Palo Alto, CA 94301 city.council@PaloAlto.gov Re: Agenda Item 15 – Support for the Dark Sky / Outdoor Lighting Ordinance Dear Mayor and Councilmembers: Green Foothills urges you to adopt a strong Dark Sky Ordinance on December 8. Protecting natural darkness is essential for the health of Palo Alto’s nature preserves, wildlife corridors, and the Baylands. Artificial light at night disrupts navigation, feeding, and reproductive cycles for wildlife and erodes the ecological integrity of the very habitats the City has worked hard to protect. Reducing unnecessary lighting is a simple, high-impact step that restores more natural nighttime conditions, limits skyglow, and strengthens the resilience of our remaining open spaces. A strong ordinance will help ensure that wildlife, residents, and future generations can continue to experience the beauty of the night sky and the ecological richness of Palo Alto’s natural areas. Thank you for your continued commitment to environmental stewardship. Sincerely, Alexandra Mendoza Environmental Associate, Green Foothills From:Tina Peak To:Council, City Subject:Please pass a Dark Sky Ordinance Date:Wednesday, December 3, 2025 4:36:58 PM CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. i Dear Mayor Lauing and Palo Alto Councilmembers, I feel that the city should quickly adopt the Dark Sky Ordinance. It is imperative to focus on protecting the environment and the wildlife that lives in our urban area. People should attempt to have the least possible impact on other animals that we share space with. Setting appropriate lights-out times, installing lower light level fixtures and preventing spill over lighting are all important components to the plan. And these are not difficult modifications to make. I look forward to seeing these common sense limits on the light pollution that is present throughout the city. Regards, Tina Peak This message needs your attention This is a personal email address. This is their first email to you. Mark Safe Report From:Lois Fowkes To:Council, City Subject:night sky Date:Wednesday, December 3, 2025 3:05:46 PM CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. Dear City Council: I am writing to support a strong ordinance in Palo Alto to keep the night sky dark, or rather, to make the night sky darker. The ambient light here is so much that birds are disoriented. It also interferes with hormone production, breeding, and migration. The lighting can even attract prey. Please recognize the value of bird life here, and protect it by keeping public lighting low. Thank you, Lois Fowkes From:Lauren Weston To:Council, City Subject:Re: Dec 8 Agenda Item 15 – Support for the Dark Sky / Outdoor Lighting Ordinance Date:Wednesday, December 3, 2025 1:31:12 PM CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. i Dear Mayor Lauing and Councilmembers: Acterra strongly encourages you to approve a robust Dark Sky (Outdoor Lighting) Ordinance on December 8. Limiting excessive outdoor lighting offers a straightforward and impactful approach to reduce energy consumption, decrease greenhouse gas emissions, and support Palo Alto's climate and sustainability objectives. Overabundance of nighttime illumination also negatively affects wildlife, interferes with human sleep patterns and well-being, and creates light pollution that degrades our community's quality of life. By directing light only to areas where it's necessary and at appropriate times, Palo Alto can enhance public health, cut emissions, and preserve the natural nighttime landscape. A comprehensive ordinance will provide both immediate and enduring advantages for residents, local ecosystems, and our climate. We urge the Council to embrace this vital measure toward building a healthier, more sustainable community. Sincerely, Lauren Weston (she/her), EMBA Executive Director Acterra: Action for a Healthy Planet (530) 219-2813 acterra.org | Subscribe Acterra staff use self-identified pronouns to support workplace inclusion for everyone. I respectfully acknowledge that my work takes place on the ancestral and unceded land of This message needs your attention This is their first email to you. Mark Safe Report Powered by Mimecast the Ramaytush Ohlone and/or the Yokutz. Whose land are you on? In alignment with our values, we practice Slow Fridays (reducing internal and external meetings to focus on other areas of our work!). From:April A. To:Council, City Subject:12/8/2025 Agenda Item 15: We need a strong Outdoor Lighting Ordinance Date:Wednesday, December 3, 2025 11:06:11 AM CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. i City Council Members: I am a resident of Palo Alto and have lived here over 30 years. My home is located directly across the street from the Fairmeadow and JLS schools. I'm very interested in seeing a strong outdoor lighting ordinance adopted to protect migrating birds, save energy, and minimize the negative impact on the residents of Palo Alto. I am regularly impacted by nuisance lighting around my home and would like a city ordinance to address this. Two neighbors behind my home have lights that are left on 24 hours a day, and both shine into my windows. Worse than that, both schools across the street routinely have bright overhead lights left on in classrooms overnight, sometimes for days and days. Not only is this annoying and visible in my home, but my tax dollars are paying for wasted energy costs. These are not outdoor security lights, they are classroom lighting that should have timers installed to turn them off. I encourage you to vote to adopt a strong ordinance to protect humans, birds, and our night sky, including the following recommended by Santa Clara Valley Bird Alliance and the Sierra Club: Require all nonessential outdoor lighting to be turned off by 11:00 PM with reasonable exceptions, rather than midnight. Require all new buildings, remodels, and fixture replacements to meet compliant lighting standards. Remove the sunset deadline that would otherwise require citywide fixture replacement. Apply the prohibition on blinking, flashing, rotating lights, as well as searchlights, aerial lasers, and spotlights, citywide, including Edgewood. Require existing adjustable lighting to be compliant within one year of the effective date of the ordinance. This message needs your attention This is a personal email address. This is their first email to your company. Mark Safe Report April Austin East Meadow Drive Palo Alto, CA From:Drey To:Council, City Subject:12/8/25 Agenda Item 15: Please reduce Light pollution Date:Tuesday, December 2, 2025 5:33:59 PM CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. i Dear Mayor Lauing and Council, I grew up in Palo Alto, and appreciated being able to look up at the night sky from my backyard and actually see the stars. That’s become much harder over the years as bright outdoor lighting has increased in neighborhoods across the city. I’m writing to ask you to adopt a strong Dark Sky Ordinance on December 8 and to include the Sierra Club’s amendment requiring nonessential lighting to be turned off by 11:00 PM. This is a small, reasonable change that will help restore some of the natural nighttime environment many of us remember. It will also reduce energy waste and help Palo Alto meet its climate goals. And for residents like me, it will make our neighborhoods feel calmer, healthier, and more connected to the natural world that surrounds us. Please strengthen the ordinance with the 11 PM shut-off. It’s the right step for our community, our health, and the environment. Thank you for your consideration. Drey Kaiser This message needs your attention This is a personal email address. This is their first email to your company. Mark Safe Report From:Ala Romanowicz To:Council, City Subject:12/8/25 Agenda Item 15: We need dark nights Date:Tuesday, December 2, 2025 5:19:22 PM CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. i Dear Mayor Lauing and Councilmembers I’m writing as a Palo Alto resident and a European immigrant who was drawn to this community partly because of its strong environmental values. Growing up in Europe, I was used to seeing cities manage lighting more thoughtfully, with earlier shut-off times and a clear awareness that darkness is part of a healthy environment. I believe Palo Alto can do the same. I strongly support the Dark Sky Ordinance, and I hope you will adopt the Sierra Club’s amendment to require nonessential lighting to turn off by 11:00 PM. This small adjustment would reduce the harsh lighting that affects sleep in many neighborhoods, cut energy waste during the quietest hours of the night, and help protect the migrating birds and insects that still move through our city. For me, part of feeling at home here is knowing that Palo Alto is committed to practices that respect both people and nature. This amendment is a practical, meaningful way to do that. Thank you, Tris This message needs your attention This is a personal email address. This is their first email to your company. Mark Safe Report 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:Tuesday, December 2, 2025 12:16:18 PM Attachments:Letter Regarding Lighting Ordinance - Edgewood Exemption and Prohibited Lighting.pdf CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. 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 Via Email [City.Council@paloalto.gov; Ed.Lauing@paloalto.gov; kelly.cha@paloalto.gov ] December 2, 2025 Honorable Mayor and Members of 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; Tentatively Scheduled for City Council Hearing on December 8, 2025 Dear Honorable Mayor and Members of the Palo Alto City Council and Ms. Cha: In our prior letter dated November 6, 2025, we pointed out a typographical error in the exemption for Edgewood properties in the proposed Lighting ordinance. Staff has acknowledged the error and recommends its correction, as do we, as follows: (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). If this language is not removed, the exemption would apply only to 15 of the 52 properties on Edgewood, which is clearly not the intent. The Santa Clara Valley Bird Alliance and the Sierra Club Loma Prieta Chapter, in their letter dated November 6, 2025, suggest that the Edgewood exemption be further modified to expressly say the properties are subject to the prohibitions in Section 18.40.250(g) (Prohibited Lighting). While well meaning, this suggestion is wrong as a matter of statutory construction and should be rejected. If this is accepted, it will infer that the other five exempt categories, including seasonal lighting, illuminated street numbers and emergency shelters, would not be subject to the prohibited lighting restriction, which is obviously not intended. As drafted, Section 18.40.250(g) prohibits certain lighting as follows: (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. The Prohibited Lighting provision applies to all properties as a matter of normal statutory interpretation. Only airport lighting is exempt. The airport exemption specifically states, “Nothing in this section shall be interpreted to restrict, limit, or otherwise regulate” airport lighting. None of the other exemptions are prefaced with this savings language. Rules of statutory construction would therefore say that, except for airport lighting, all of the exempt categories in Section 18.40.250(d) remain subject to the Prohibited Lighting provision. If, as requested by the environmental advocates, the exemption for Edgewood Drive properties—but not any of the other five exemption categories—were made expressly subject to the Prohibited Lighting provision, rules of construction would compel the opposite interpretation that the other five exempt categories are not subject to the prohibitions. This would lead to confusion and illogical outcomes. It would mean, for example, that seasonal lighting displays could include searchlights, spotlights and aerial lasers (Section 18.40.250(d)(4)). Illuminated street numbers could have rotating or flashing lights (Section 18.40.250(d)(1)). Emergency Shelters would be free to employ blinking, flashing or rotating outdoor lighting and searchlights (Section 18.40.250(d)(6)). The request to add specific reference to prohibited lighting in the Edgewood exemption should be declined because it is unnecessary and would result in confusion and the unintended consequence of the reading out the prohibited lighting limitations on the other exemptions. Respectfully submitted, 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