HomeMy WebLinkAboutStaff Report 2512-5753CITY OF PALO ALTO
CITY COUNCIL
Special Meeting
Monday, March 16, 2026
Council Chambers & Hybrid
4:30 PM
Agenda Item
14.Adoption of an Ordinance Adding a New Section 18.40.280 (Bird-Friendly Design) to
Chapter 18.40 (General Standards and Exceptions) of Title 18 (Zoning) of the Palo Alto
Municipal Code; CEQA Status: Exempt Pursuant to CEQA Guidelines Section 15308
(Actions for Protection of the Environment) Public Comment, Staff Presentation
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City Council
Staff Report
From: City Manager
Report Type: ACTION ITEMS
Lead Department: Planning and Development Services
Meeting Date: March 16, 2026
Report #:2512-5753
TITLE
Adoption of an Ordinance Adding a New Section 18.40.280 (Bird-Friendly Design) to Chapter
18.40 (General Standards and Exceptions) of Title 18 (Zoning) of the Palo Alto Municipal Code;
CEQA Status: Exempt Pursuant to CEQA Guidelines Section 15308 (Actions for Protection of the
Environment)
RECOMMENDATION
Staff recommend the City Council adopt an Ordinance adding a new Section 18.40.280 (Bird-
Friendly Design) to Chapter 18.40 (General Standards and Exceptions) of Title 18 (Zoning) of the
Palo Alto Municipal Code.
EXECUTIVE SUMMARY
The Bird-Friendly Design Ordinance (Draft Ordinance) implements Comprehensive Plan
Program L6.3.1, which directs staff to develop guidelines that minimize hazards for birds, and
has been a City Council Priority objective for several years. The Draft Ordinance (Attachment A)
incorporates modifications recommended by the Planning and Transportation Commission
(PTC) following its public hearing on December 10, 2025. The Draft Ordinance generally applies
to new construction and major remodels involving unbroken glazing of 24 square feet or larger.
The Draft Ordinance regulates residential and nonresidential projects within or outside of Bird
Sensitive Area differently, with stricter requirements apply to those within the Bird Sensitive
Area.
Acknowledging the high cost and limited availability of specialized glazing, the PTC
recommended specific modifications to mitigate impacts on housing production, most notably
exempting any portions of residential structures under 35 feet in height located outside the
Bird Sensitive Area. This recommendation effectively exempts all single-family homes outside of
Bird Sensitive Area from the new regulations, reflecting the PTC’s concern that current market
realities and supply chain constraints disproportionately burden smaller-scale residential
projects. Additionally, the PTC directed the removal of requirements for the replacement of
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existing fenestration to further reduce logistical hurdles for homeowners as well as local
businesses.
BACKGROUND
1 and July 18, 2024.2 The
ARB recommended tailoring the Draft Ordinance to different areas within the City (e.g.,
foothills, Baylands, and urbanized areas) and exempting residential projects to avoid increasing
housing costs. The ARB recommended considering “substantial remodel” as the threshold for
triggering requirements for the Draft Ordinance, using window size limitations, and expressed
some concerns about how these standards could affect residential development.
On August 28, 2024,3 the PTC reviewed the Draft Ordinance with a focus on simplifying
applicability and mitigating development costs, recommending reduced buffers and the use
of non-permanent markers to avoid hindering housing production.
On October 30, 2024,4 staff subsequently presented the revised Draft Ordinance,
establishing key definitions, applicability, and types of Bird-Friendly Treatments to facilitate
1 February 15, 2024, ARB Staff Report Packet (Item #3), starting on Page 130
2 July 18, 2024, ARB Staff Report Packet (Item #3), starting on Page 130
3 August 28, 2024, PTC Staff Report Packet (Item #2), starting on Page 9
4 October 30, 2024, PTC Staff Report Packet (Item #2), starting on Page 10
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easier implementation. The PTC moved to recommend the Draft Ordinance to City Council
but requested specific modifications, including expanding applicability to additional project
types and amending the location and amount of required treatments. Additionally, the PTC
directed revisions to definitions, such as the Bird Sensitive Area, and changes to the criteria
for alternative compliance
On December 10, 2025,9 staff returned with a revised Draft Ordinance and new research on
cost and availability of specialized glazing (described in more detail in the PTC Staff Report,5
and below), encouraging the PTC to reconsider residential requirements based on
feasibility. Acknowledging financial burdens, the PTC accepted most modifications staff
recommended and added an exemption for residential structures (exempting any portions
of residential structures under 35 feet). Despite these changes, the PTC remained uncertain
regarding the local significance of bird strikes and debated whether these regulations
should be adopted as an ordinance or simply as guidelines.
The final recommendation was for approval of the Draft Ordinance with modifications (as
described in Attachment C) by a vote of 5-2, with Commissioners Hechtman and James voting
against the motion. Commissioner James expressed concerns about whether the regulations
were justified and effective. Commissioner Hechtman appreciated how far these regulations
have come but expressed concerns with whether the difference in regulations between
residential and commercial uses was appropriate, and whether the regulations were still too
strict for residential uses in the Bird Sensitive Area.
Cost and Availability of Bird-Friendly Glazing
Following the PTC direction from October 2024, staff identified concerns regarding the
disproportionate cost and limited availability of specialized glazing for small-scale projects like
single-family homes. Through conversations with glass manufacturers, architects, local retailers,
and other cities, staff learned that a dedicated residential market for these products does not
currently exist, forcing homeowners to source commercial-rated glazing that is significantly
more expensive and difficult to procure directly. Architects noted that while specialized glazing
offers better visibility, the high unit cost, which are often double that of standard options, and
extended lead times might make it practically prohibitive for many residential projects. As a
result, the glazing specialists typically recommend alternatives like insect screens, which is the
cheapest option when architecturally compatible, or non-permanent markers like films, though
the latter present challenges regarding installation, bulk purchasing requirements, and
environmental waste.
Discussions with other cities confirmed that their ordinances essentially exempt single-family
homes. However, when bird-friendly design features are required, applicants generally propose
insect screens as part of their applications or staff would recommend revisions to architectural
features and materials to mitigate the high cost and limited availability of specialized glazing.
9 December 10, 2025, PTC Staff Report Packet (Item #2), starting on Page 100
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Local retailers similarly reported a lack of inventory and awareness, indicating that any request
for specialized glazing would require special orders from manufacturers, potentially delaying
construction timelines. Given these constraints, other cities often exempt single-family homes
outright or limit requirements to new construction to mitigate the financial burden. Ultimately,
additional research highlighted that mandating specialized glazing for residential projects
introduces substantial logistical hurdles and costs, as the current supply chain is not equipped
to support individual procurement efficiently.
ANALYSIS
Definitions. Defines key terms pertaining exclusively to this ordinance, including, but not
limited to, Bird Hazard Installation, Bird Sensitive Areas (hillsides and Baylands), Bird-
Friendly Treatments (visual cues such as dots or lines spaced maximum 2 inches apart for
permanent installations, residential-only limited applications (decals/films), and exterior
features like screens).
Applicability. Applies to new construction, major remodels, and all new fenestration or new
or replacement Bird Hazard Installation.
Bird-Friendly Design Requirements.
o Mandating Bird-Friendly Treatments for all Bird Hazard Installations and for any
unbroken glazing on an elevation that is 24 square feet or larger.
o For residential, within the Bird Sensitive Area, up to 10% of an elevation may be
untreated; outside of the Bird Sensitive Area, up to 40% may be untreated.
o For nonresidential, up to 10% of an elevation may be untreated, regardless of location.
Alternative Compliance. Allows alternative approaches for any projects seeking to meet the
intent of the ordinance through methods other than those specifically prescribed, subject to
Director approval.
Exemptions for some structures, including historic buildings, 100% affordable housing
projects, first-floor commercial street-facing glazing in specified districts, and any portions
of residential structures under 35 feet in height.
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Exemption on Small-Scale Projects
POLICY IMPLICATIONS
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production by reducing project viability and potentially delaying approval for critical housing
units.
FISCAL/RESOURCE IMPACT
STAKEHOLDER ENGAGEMENT
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justify the associated costs. Both entities urge the City to reconsider highly restrictive glazing
mandates, such as the 10% limit on untreated glass and the 24 square foot treatment threshold
for replacements, which they argue will dramatically increase construction costs, strain supply
chains, and negatively impact the aesthetics and marketability of projects. They recommend
that the City instead conduct a justifying study or adopt more practical, targeted alternatives,
such as exempting retail/lobby areas or narrowly defining the Bird Sensitive Area.
ENVIRONMENTAL REVIEW
ATTACHMENTS
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Attachment B: Draft Bird Sensitive Area Map
APPROVED BY:
*** NOT YET APPROVED ***
0160152_20260303_ay
Ordinance No. _____
Ordinance of the Council of the City of Palo Alto Amending Chapter 18.40
(General Standards and Exceptions) of Title 18 (Zoning) of the Palo Alto
Municipal Code to Adopt Bird Friendly Design Standards
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. On November 13, 2017, the City Council adopted the 2030 Comprehensive Plan. The
plan included a policy encouraging bird-friendly design and a program to develop
guidelines for bird-friendly building design that minimizes hazards for birds and reduces
the poten al for collisions.
B. On January 29, 2024, the City Council selected four City Council priori es, one of which
is “Climate Change & Natural Environment – Protec on & Adapta on.” This priority
includes an objec ve to approve a bird-safe glass and wildlife light pollu on protec ons
ordinance.
C. On February 14, 2024, and July 18, 2024, the Architectural Review Board conducted
study sessions and provided feedback on this ordinance.
D. On August 14, 2024, the Planning and Transporta on Commission reviewed the dra
ordinance, provided feedback, and con nued the hearing to a date uncertain.
E. On October 30, 2024, the Planning and Transporta on Commission ini ally reviewed the
proposed ordinance and recommended its adop on to the City Council.
F. On December 10, 2025, a er considering addi onal informa on presented by staff, the
Planning and Transporta on Commission again recommended adop on of the ordinance
to the City Council.
G. This Ordinance is intended to reduce bird mortality rates by reducing the possibility of
bird collisions with buildings, contribu ng to a healthier and more resilient environment.
H. This Ordinance provides clear and consistent standards, streamlining the approval
process by reducing the need for case-by-case review of individual projects.
SECTION 2. Section 18.40.280 (Bird-Friendly Design Standards) of Chapter 18.40
(General Standards and Exceptions) of Title 18 (Zoning) of the Palo Alto Municipal Code is
added to read as follows:
18.40.280 Bird-Friendly Design Standards
(a) Purpose. The intent of this section is to establish bird-friendly design standards for glass to
minimize hazards for birds and to reduce the potential for collisions.
*** NOT YET APPROVED ***
0160152_20260303_ay
(b) Definitions. The following terms are defined for the purposes of this section:
(1) “Bird Sensitive Area” means the areas located east of Highway 101 and west of
Foothill Expressway.
(2) “Bird-Friendly Treatment” means treatment to glazing that provides visual cues to
birds and reduces the likelihood of bird collisions by incorporating one of the
following:
(A) Patterned Treatment, Permanent. Glazing shall be permanently translucent or
obscured, or include patterns are etched, fritted, stenciled, silk-screened, or
otherwise permanently incorporated into the transparent material.
(i) For patterns using dots or other isolated solid shapes, each dot or shape
must be at least a 1/4 inch in diameter and be no more than 2 inches apart in
any direction.
(ii) For patterns using lines, they must be at least 1/8 inch in width and spaced
no more than 2 inches apart.
(iii) Frit, ceramic ink, or other marker types must be opaque, permanently
adhered, and durable for the life of the glazing, unless an alternative
compliance method is chosen as outlined in Section 18.40.280(e).
(B) Patterned Treatment, Limited. Films, decals, or other similar markers may be
used only for residential development or the residential portion of mixed-use
development. These Limited Patterned Treatments shall have the same visual
cues or patterns as Permanent Patterned Treatment under 18.40.280(b)(2)(A)
and be applied to the outer surface to the extent as possible.
(C) Exterior Features. Panes with exterior screens, shutters or shading devices
installed permanently over windows, structures, or building features such that
there is no gap larger than 9 inches in one dimension. Exterior features include,
but are not limited to, metal screens, insect screens, shutters, window grilles,
fixed solar shading such as louvres, and exterior insert, brise soleil, or solar
screens.
(3) “Bird Hazard Installations” are defined as visually unbroken, exterior glazing and/or
glass panels that are reflective or transparent that provide a clear line of sight
through the glazed elements to porches, courtyards, water features, trees,
vegetation, landscaping, or the sky on the other side of the glazed element,
including, but not limited to: (A) Free standing features such as transparent awnings,
(B) Transparent handrails and guards, (C) Transparent wind break panels, acoustic
barriers, bus, weather shelters, other free-standing transparent walls, or see-
through building protrusions; (D) Transparent skyways or walkways; (E) Two or more
parallel transparent elements with a distance of 30 feet or less between them, when
at least one of the parallel panes is 24 square feet or larger; or (F) Two or more
*** NOT YET APPROVED ***
0160152_20260303_ay
transparent elements on opposing sides and within 12 feet of a corner
(perpendicular, acute, or obtuse) when at least one of the panes is 24 square feet or
larger.
(4) “Elevation” means any exterior walls of a building or structure, as seen from a two-
dimensional perspective like the front, side, or rear.
(5) “Fenestration” means the openings in a building’s façade, such as door, skylights,
and windows.
(6) “Glazing” means the reflective, transparent or translucent materials that fill
openings in a building’s exterior walls. This typically includes glass but can also
encompass other materials like plastic or acrylic sheets that allow light transmission.
(c) Applicability. The bird-friendly design requirements apply to any of the following projects,
when a permit is otherwise required:
(1) All newly constructed structures and buildings;
(2) Substantial Remodel, as defined in Section 16.14.070 of the Code; or
(3) Any new fenestration or new or replacement Bird Hazard Installations.
(d) Bird-Friendly Design Requirements
(1) Basic Requirement. Bird-Friendly Treatment is required for all Bird Hazard
installations and all glazing on an elevation of a building or structure that is
unbroken and 24 square feet or larger in size.
(2) Residential and the residential portion of mixed-use development.
(A) Within the Bird Sensitive Area, in addition to the requirements of (d)(1), no more
than ten percent of an elevation of any structure or building shall be untreated
glazing.
(B) Outside of the Bird Sensitive Area, in addition to the requirements of (d)(1), no
more than 40 percent of an elevation above 35 feet of any structure or building
shall be untreated glazing.
(3) Nonresidential and the nonresidential portion of mixed-use development. In
addition to the requirements of (d)(1), no more than ten percent of an elevation of
any structure or building shall be untreated glazing.
(e) Alternative Compliance. Property owners or applicants may request an alternative means of
compliance with requirements established in Section 18.40.280(d). The alternative shall be
recommended in a report by a biologist or ornithologist holding a degree in wildlife biology
or a specialization in ornithology, and having experience in bird-friendly building design. The
request shall be submitted and reviewed in accordance with the applicable procedures in
*** NOT YET APPROVED ***
0160152_20260303_ay
Chapter 18.77, and is subject to approval by the Director. The proposed alternative
compliance shall:
(1) Reduce the risk of bird collision to a level equivalent to or less than that which would
result from strict compliance with Section 18.40.280(d); and
(2) Be consistent with the intent of this section as set forth in Section 18.40.280(a).
(f) Lighting. All projects shall comply with the outdoor lighting requirements pursuant to
Section 18.40.250 of the Municipal Code.
(g) Exemptions. The following types of projects shall be exempt from Section 18.40.280(d):
(1) Any historic structure located within the City’s Historic Districts or listed on the City’s
Historic Inventory or the State or National Historical Registers, except for new
additions where treatment conforms to Secretary of Interior Standards for
Rehabilitation of Historic Properties.
(2) The first floor of commercial uses facing a public street, up to 14 feet in height,
within the following districts:
(A) Retail Shopping (R) Combining District
(B) Pedestrian Shopping (P) Combining District
(C) Ground Floor (GF) Combining District
(D) North Ventura Coordinated Area Plan Districts
(3) 100% affordable housing projects as defined in Section 18.32.030.
(4) Accessory Dwelling Units and Junior Accessory Dwelling Units pursuant to Chapter
18.09.
(5) Outside of the Bird Sensitive Area, any portions of residential structures under 35
feet.
(h) California Building Code. All windows, doors, or other features must comply with the
requirements of the California Building Code including the fire hazard severity zone
regulations in California Green Buildings Standards Code (CALGreen). Should a conflict exist
with the provisions of this section, the standards in the California Building Code shall
prevail.
SECTION 3. If any section, subsection, clause or phrase of this Ordinance is for any
reason held to be invalid, such decision shall not affect the validity of the remaining portion or
sections of the Ordinance. The Council hereby declares that it should have adopted the
Ordinance and each section, subsection, sentence, clause or phrase thereof irrespective of the
fact that any one or more sections, subsections, sentences, clauses or phrases be declared
invalid.
*** NOT YET APPROVED ***
0160152_20260303_ay
SECTION 4. 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 5. This ordinance shall be effective on the thirty-first day following its
adoption.
SECTION 6. Pipeline Projects. This Ordinance shall not apply to any project
application deemed complete prior to the effective date of this Ordinance. Any project
completed pursuant to such application shall be deemed a legal non-conforming structure
and/or use, subject to the provisions of Palo Alto Municipal Code Chapter 18.70.
INTRODUCED:
PASSED:
AYES:
NOES:
ABSENT:
ABSTENTIONS:
NOT PARTICIPATING:
ATTEST:
____________________________ ____________________________
City Clerk Mayor
APPROVED AS TO FORM: APPROVED AS TO CONTENT:
____________________________ ____________________________
Assistant City Attorney City Manager
____________________________
Director of Planning & Development
Services
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From:Tiffany Griego
To:Council, City; Clerk, City
Cc:Lait, Jonathan; Shweta Bhatnagar; Armer, Jennifer; Frick, Coleman; Cha, Kelly; Kelly Kline; Jamie S. Jarvis; Diana
O"Dell; Jean G. Snider
Subject:3/16 City Council hearing on the Bird-Friendly Design Ordinance
Date:Friday, March 6, 2026 12:40:09 PM
Attachments:2026-03-05__Bird Safe Buildings Comment Letter - Stanford University.pdf
CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links.
Dear Mayor Veenker and Members of the City Council,
Please find enclosed Stanford University’s comments related to the draft Bird-Friendly Ordinance
related to impacts to Stanford Research Park ad Shopping Center.
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>
Date: Friday, March 6, 2026 at 10:33 AM
Cc: "Cha, Kelly" <Kelly.Cha@paloalto.gov>
Subject: 3/16 City Council hearing on the Bird-Friendly Design Ordinance
Hello everyone -
I would like to share with you that the Bird-Friendly Design Ordinance will be heard before the City
Council on March 16, 2026. Please check out the online agendato see the staff report and associated
attachments. The ordinance is scheduled as Item #14 under Action Items. Please be informed that
the time estimated on the agenda is an estimate, but could be changed as the council discussion
progresses.
If you would like to send written comments or provide oral comments at the hearing, either in
person or virtually, please read the PUBLIC COMMENTS section of the online agenda.
If you have any questions, please do not hesitate to contact me.
Thank you for your continued participation in this effort,
Kelly Cha (she/her)
Senior Planner
Planning and Development Services
(650) 329-2155 | Kelly.Cha@PaloAlto.gov
www.PaloAlto.gov
March 5, 2026
Palo Alto City Council
City of Palo Alto
250 Hamilton Avenue
Palo Alto, CA 94301
VIA EMAIL City.Council@PaloAlto.gov
Re: City Council Consideration of Bird-Friendly Design Ordinance
Dear Mayor Veenker and Members of the City Council,
On behalf of Stanford University and Stanford Research Park, I would like to extend our sincere
gratitude to City staff for their continued hard work on the proposed Bird-Friendly Design
Ordinance. In this letter, we reiterate the concerns shared with the City over the past months,
including those raised during the January webinar for business owners. As the landowner of
the Stanford Research Park and Shopping Center, we are concerned that the proposed
ordinance poses significant design and implementation challenges for remodels and new
construction, particularly new residential construction.
We strongly recommend that City Council revise the ordinance to (1) limit the new
restrictions to office/R&D properties located within the Bird Sensitive Area boundaries
that were originally recommended by the PTC, and (2) exempt all residential buildings
regardless of location within the City. The reasons are many:
1. The draft ordinance as written, which includes triggers for window replacement, would
force landlords in Stanford Research Park to retrofit all windows with bird-friendly
glazing even if tenant-required remodeling or repositioning scope would otherwise
exclude existing windows. Forcing landlords to replace windows when they otherwise
would not opt to is so costly that it would put a chill on proactive reinvestment in the
existing building stock in SRP. Over time, without proactive reinvestment, SRP would
see a gradual degradation, affecting business and property tax revenue generation.
2. Staff has acknowledged the added cost burden resulting from this draft ordinance,
which would curtail the construction of new high-density residential development,
when this product type is already challenged by the high-cost burden.
3. The City should not make policy without data and a valid justification for including sites
that are outside of a riparian corridor or migratory path.
Targeted Regulations: The current requirements do not consider the diverse conditions
throughout the City, and there is limited reliable data on bird-building conflicts in areas beyond
the designated Bird Sensitive Area. As a viable alternative, we suggest adopting San Francisco’s
Bird-Safe Building Standards, which provide a more nuanced approach by limiting required
treatments to buildings in expansive open spaces or near water, as well as specific
architectural features that may pose a bird hazard. This approach represents a more balanced
strategy, avoiding a one-size-fits-all approach throughout the City. We support targeted
regulations that focus on the specific Bird Sensitive Areas and exempt new residential
construction.
Insufficient Data: While we understand that the ordinance aims to mitigate bird collisions,
there is no comprehensive data that speaks to the scope of this issue. The proposed ordinance
would require fairly sweeping changes throughout the City based on insufficient data. To date,
we are unaware of any documented bird collisions within Stanford Research Park and
Shopping Center. Since most of our buildings are two stories tall and not situated on a flyway
or riparian corridor, we believe it is crucial to conduct a data-driven assessment of local
collision frequencies, risk factors, and anticipated outcomes to justify the extensive breadth
and costs of these requirements. As was called for in the Comprehensive Plan Policy L-6.3,
we respectfully request that the City undertake a study before developing guidelines for
bird-friendly design (rather than this ordinance).
Altered User Experience, Limited Supply Chain, and Higher Costs: The use of bird-friendly
glass significantly impacts building occupants' experiences due to the visible lines and dots on
windows, which detract from aesthetic appeal, especially without clear evidence of local
benefits. The ordinance suggests allowing only 10% untreated glazing on any non-residential
elevation citywide, requiring commercial buildings to have permanent glass treatments with
patterns no more than two inches apart to minimize collision risks for birds. This broad
requirement fails to consider essential factors like overall benefits, occupant experience, and
construction costs, especially new residential construction. (See Ex. A for example photos
taken at 3215 Porter Drive.) It inadvertently increases expenses while negatively impacting user
experiences. Additionally, the limited availability of bird-friendly treatment materials raises
concerns that a sudden demand increase could strain resources and delay projects,
highlighting the need for a reliable supply chain before implementing any mandates. We urge
the City to adopt an approach that allows a broader range of practical alternatives outside
of permanent glazing treatments.
In conclusion, we encourage the City to maintain Palo Alto's appeal to businesses while
exploring bird-friendly design options and non-binding guidelines that align with best
practices from neighboring jurisdictions. Stanford Research Park already balances
environmental initiatives and economic viability. We have voluntarily installed bird-glass
on all bus shelters and in some new developments in SRP near potential migratory paths.
We appreciate your consideration, and please let me know if you have further questions at
tgriego@stanford.edu.
Sincerely,
Tiffany Griego,
Senior Managing Director
Stanford Real Estate, Stanford University
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
Exhibit A:
Bird-glass film, installed voluntarily at 3215 Porter Drive, shows the significant compromise to
user experience.
From:Laura Bowser
To:Council, City; Lait, Jonathan; Armer, Jennifer; Cha, Kelly
Subject:Bird-Friendly Design Ordinance (March 16, 2026 - Agenda Item #14)
Date:Monday, March 16, 2026 10:05:32 AM
Attachments:SHP Letter re Bird Ordinance - Mar 16 2026.pdf
CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links.
Councilmembers of the City Council,
Please see attached for our comments regarding the proposed Bird Safe Ordinance under
consideration at tonight’s meeting.
Best,
Laura
Laura Bowser
Sand Hill Property Company
2600 El Camino Real, Suite 410
Palo Alto, CA 94306
Tel. +1 650 344 1500
2600 El Camino Real, Suite 410 | Palo Alto, California 94306
March 16, 2026
Re: Ordinance re: Bird-Friendly Design (Council Hearing March 16, 2026 – Item #14)
Dear Mayor and Members of the City Council:
On behalf of Sand Hill Property Company (SHP), we are writing regarding the proposed Bird-Friendly
Design Ordinance (Ordinance). SHP values its longstanding working relationship with the City and is
committed to delivering and maintaining high quality projects that support the City’s goals, including new
housing and reinvestment in existing development.
We appreciate the work that Planning staff has undertaken to address a challenging issue. However, SHP
respectfully urges the City Council not to adopt the Ordinance in its current form and instead allow
staff additional time to conduct further analysis before adopting a policy with significant impacts.
While SHP supports the City’s objective of addressing legitimate bird-safety concerns, the current
Ordinance imposes a sweeping solution before the City has adequately diagnosed the problem it is trying
to solve. The Ordinance is not sufficiently tailored to local conditions and will create substantial
unintended consequences for existing property owners, future investment, and new development without
evidence that such a broad approach is warranted. These concerns echo the substantial stakeholder
feedback already provided to the Planning Commission and City Council, which has consistently called
for additional study and a more carefully tailored ordinance before adoption.
These concerns are particularly important given the City’s substantial RHNA obligations and its ongoing
need to facilitate multifamily housing production. As drafted, the Ordinance would materially affect the
design, cost, and feasibility of multifamily residential and other projects at a time when the City should be
focused on removing unnecessary barriers to housing and reinvestment.
For these reasons, SHP respectfully requests that the City Council defer adoption of the proposed
Ordinance and instead direct staff to return with a more fully studied proposal that better
considers local conditions, best practices, and engagement with stakeholders. The Ordinance needs
to address the actual risks and adopt an approach that can effectively address real bird-safety
concerns without inadvertently creating significant new problems.
Mayor and Members of the City Council,
City of Palo Alto
City.Council@cityofpaloalto.org;
Ed.Lauing@cityofpaloalto.org;
Vicki.Veenker@cityofpaloalto.org;
Julie.LythcottHaims@cityofpaloalto.org
Pat.Burt@cityofpaloalto.org;
Greer.Stone@cityofpaloalto.org;
George.Lu@cityofpaloalto.org;
Keith.Reckdahl@cityofpaloalto.org
* * *
Thank you for your time and attention to this issue. We look forward to continuing to work with Planning
staff and decisionmakers on an approach that addresses bird-safety concerns in a practical and effective
manner.
Sincerely,
Laura Bowser
Director, Development
Sand Hill Property Company
Copies:
Jonathan Lait, Director, Planning & Development Services
Jonathan.Lait@CityofPaloAlto.org
Jennifer Armer, Asst. Director, Planning & Development Services
Jennifer.Armer@CityofPaloAlto.org
Kelly Cha, Senior Planner, Planning & Development Services
Kelly.Cha@CityofPaloAlto.org
From:Tom Fountain
To:Council, City
Cc:Cha, Kelly
Subject:"Bird-Friendly" Design Ordinance
Date:Sunday, March 15, 2026 9:42:53 PM
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Dear Mayor Veenker and Members of the City Council,
With respect to the proposed "Bird-Friendly" Design ordinance, I am writing in support of an
exemption for residential buildings.
Specifically:
Lack of Local Bird-Collision Studies. There are no data or studies of
bird collisions in Palo Alto, commercial or residential, nor any in neighboring
jurisdictions. The advocates for this new ordinance generally base their conclusions
on studies conducted elsewhere covering different species of birds with different
migratory patterns. Analyses of the relevant bird species, their propensity to collide,
and impact of conservation efforts are needed before imposing costs on property
owners.
The Burden of Compliance on Residential Development is Substantial. Bird-safe
glass windows for residential use are not readily available and are prohibitively
expensive. The alternatives of permanent metal screens and shades are impractical,
expensive, aesthetically unappealing, obscure visibility, and are unsafe for fire
escape. Similarly, the alternative of plastic dots or films are impractical and pollute
the environment with microplastics and PFASs. Homes need unobstructed windows
for safety to keep an eye on our children and see who is on the property. These
burdens combine to unfairly reduce market value and slow housing development.
Adopt Non-Mandatory Bird-Friendly Design Guidelines. Direct staff to prepare and
adopt guidelines consistent with the Comprehensive Plan’s authorization. Voluntary
uptake under design review, combined with staff encouragement and public outreach,
can generate meaningful real-world experience with residential bird-safe design in
this community.
Follow the Lead of San Francisco, Richmond, Alameda and Berkeley. If residences
are to be regulated, the city should follow the lead of San Francisco, Richmond,
Alameda and Berkeley, as recommended by the Planning & Transportation
Commission. These cities exclude residential homes unless over 45 or 35 feet and
with large facade of glass (e.g., 50% or more glass), in which case, the bird-safe
requirements apply to large glass panels (e.g., 24 square feet or more). These cities
reached a fair balance of benefit against burden and give home designers a choice
Thank you,
Tom Fountain
From:Shani Kleinhaus
To:Council, City
Cc:Clerk, City; Cha, Kelly; Dash Leeds
Subject:Bird-Friendly Design Ordinance – Context from other Bay Area ordinances
Date:Sunday, March 15, 2026 2:35:45 PM
Attachments:Palo Alto Updated Applicability Table (3).pdf
Palo Alto Bird Safety Standards (raw language) comparison (3).pdf
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Bird-Friendly Design Ordinance – Context from Other Cities
Dear Mayor Veenker and Councilmembers,
We prepared the attached comparison tables (Sheet 1 Applicability,Sheet 2 Standards) to
show how Palo Alto’s proposed Bird-Friendly Design Ordinance fits within policies already
adopted by other Bay Area jurisdictions.
Cities in the region have adopted a broad spectrum of applicability and standards for
bird-friendly design.
Palo Alto’s proposed ordinance falls in the middle of this range. It is the result of many
years of vetting by multiple city boards, commissions and the community, and over
time, its applicability and scope have narrowed. We believe that it now represents a
reasonable, Palo Alto appropriate result.
The proposed standards fall well within the mainstream of current practice. Other cities
use similar bird-friendly glazing requirements, limits on untreated glass, and design
standards for hazardous features such as transparent corners, skyways, glass railings,
and other large reflective or see-through surfaces.
The comparison also shows that bird-friendly standards are commonly applied to both
residential and non-residential development and typically focus on lower building
elevations where most bird collisions occur.
Importantly, several jurisdictions that have adopted bird-friendly design requirements
have also received state recognition as Prohousing Designated Jurisdictions.This
demonstrates that adopting bird-friendly design standards is compatible with housing
production and does not impede a city’s ability to obtain or maintain Prohousing
designation.
Bird-friendly design ordinances are now a common planning tool that can protect wildlife
while remaining compatible with Palo Alto's housing goals.
Respectfully,
Shani Kleinhaus
Shani Kleinhaus, Ph.D.
Environmental Advocate
Santa Clara Valley Bird Alliance
22221 McClellan Rd.
Cupertino, CA 95014
650-868-2114
shani@scvbirdalliance.org
From:Diane McCoy
To:Council, City
Subject:Please protect birds
Date:Sunday, March 15, 2026 9:29:10 AM
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Dear Mayor Veenker and Palo Alto Councilmembers,
My name is Diane McCoy and have been a Palo Alto resident since 1978.
Before that, since 1959 I have spent all my childhood summers in Palo Alto, 'summer
camping' at my grandma's house. My grandma and grandpa's love of Palo Alto,
especially it's neighborhood parks and bay lands (sooooo many walks to the Duck
Pond!) greatly influenced my appreciation for being able to be a resident here.
Since 1959 (and earlier even) Palo Alto has continued to grow and grow and grow, in
many ways, as it happens in life. But I've always been proud and appreciative of the
way our city usually advocates and supports environmental values; we have almost
all electric everything (heaters, a/c/ stove, water heater, solar panels, etc.) thanks
partly to city supportive measures.
Please continue that legacy.
Thus, I am writing to ask you to adopt the Bird-Friendly Design Ordinance as drafted.
Please reject staff-recommended changes that could weaken the ordinance, such as
expanding the 35-foot exemption to all development types. Most bird collisions occur
at tree-canopy height, and expanding this exemption would remove protections where
they are most needed.
There are many bird-safe window treatments and design options available, and these
should be used rather than exempting commercial buildings.
Thank you for your service to our community.
Diane McCoy
Greer Road
From:Prisha Goel
To:Council, City
Subject:Subject: Support for the Bird-Friendly Design Ordinance
Date:Sunday, March 15, 2026 12:49:38 AM
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Dear Mayor Veenker and Palo Alto Councilmembers,
My name is Prisha Goel, and I am a junior at PAMC passionate about the preservation of our
local wildlife. I noticed our city is harming the lives of many birds. Living in Palo Alto, I
have had the opportunity to observe the vibrant birdlife that enriches our community.
However, I have also witnessed the tragic consequences of bird strikes, which have made me
acutely aware of the need for protective measures.
I am writing to urge you to adopt the bird-friendly design ordinance as it is currently
drafted. It is crucial to reject any staff-recommended changes that could weaken this
ordinance, particularly the proposal to expand the 35-foot exemption to all development types.
Most bird collisions occur at tree-canopy height, and expanding this exemption would
significantly diminish the protections where they are most needed.
There are numerous bird-safe window treatments and design options available that can be
integrated into new developments. I believe we should prioritize these solutions instead of
exempting commercial buildings from necessary safeguards.
Thank you for your commitment to our community and for considering the well-being of our
local bird populations.
Sincerely,
Prisha Goel
6507889694
Palo Alto Middle College
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From:Emily Renzel
To:Council, City
Subject:Please support bird friendly windows
Date:Saturday, March 14, 2026 5:28:23 PM
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Dear Mayor Veenker & Members of the City Council.
Please adopt the Bird-Friendly Design Ordinance as drafted. It is particularly important in our
Baylands which are critical to bird migrations.
Please reject staff-recommended changes that could weaken the ordinance, such as expanding
the 35-foot exemption to all development types. Most bird collisions occur at tree-canopy
height, and expanding this exemption would remove protections where they are most needed.
There are many bird-safe window treatments and design options available, and these should be
used rather than exempting commercial buildings.
Thank you for protecting Palo Alto’s birds.
Sincerely,
Emily M. Renzel
Councilmember 1979-1992
Planning Commissioner 1973-79
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From:Avroh Shah
To:Council, City
Subject:In Support of a Strong Bird-Friendly Building Ordinance
Date:Saturday, March 14, 2026 5:18:03 PM
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Dear Mayor Veenker and Palo Alto Councilmembers,
I hope you are all doing well. My name is Avroh, and I'm a junior at Paly. I think birds are
pretty amazing, and I don't think it's fair to birds when they are harmed after ramming into
barriers that are invisible to them. I have witnessed four bird strikes (two of which were fatal)
in Palo Alto during my lifetime.
I am writing to ask you to adopt the Bird-Friendly Design Ordinance as drafted.
Please reject staff-recommended changes that could weaken the ordinance, such as expanding
the 35-foot exemption to all development types. Most bird collisions occur at tree-canopy
height, and expanding this exemption would remove protections where they are most needed.
There are many bird-safe window treatments and design options available, and these should be
used rather than exempting commercial buildings.
Thank you for your service to our community.
Sincerely,
Avroh Shah
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From:Kristin Sato
To:Council, City; Cha, Kelly
Subject:"Bird-Friendly" Design Ordinance
Date:Saturday, March 14, 2026 4:32:31 PM
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Palo Alto City Council, city.council@PaloAlto.gov
Kelly Cha, kelly.cha@paloalto.gov
Re: "Bird-Friendly" Design Ordinance
Dear Mayor Veenker and Members of the City Council,
With respect to the proposed "Bird-Friendly" Design ordinance, I am writing in
support of an exemption for residential buildings. Specifically:
Lack of Local Bird-Collision Studies. There are no data or studies of birds in
Palo Alto colliding with buildings, whether commercial or residential. Analyses
of the relevant bird species, their propensity to collide under the circumstances
and their conservation risk are required to assess the risk to birds from houses.
The Burden of Compliance on Residential Development is Substantial. Bird-
safe glass windows for residential use are not readily available and are
prohibitively expensive. The alternatives of permanent metal screens and
shades are impractical, expensive, aesthetically unappealing, obscure visibility,
and are unsafe for fire escape. Similarly, the alternative of plastic dots or films
are impractical and pollute the environment with microplastics and
PFASs. Homes need unobstructed windows for safety to keep an eye on our
children and see who is on the property. These burdens combine to unfairly
reduce market value and slow housing development.
Adopt Non-Mandatory Bird-Friendly Design Guidelines. Direct staff to prepare
and adopt guidelines consistent with the Comprehensive Plan’s authorization.
Voluntary uptake under design review, combined with staff encouragement and
public outreach, can generate meaningful real-world experience with residential
bird-safe design in this community.
Follow the Lead of San Francisco, Richmond, Alameda and Berkeley. If
residences are to be regulated, the city should follow the lead of San Francisco,
Richmond, Alameda and Berkeley, as recommended by the Planning &
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Transportation Commission. These cities exclude residential homes unless
over 45 or 35 feet and with large facade of glass (e.g., 50% or more glass), in
which case, the bird-safe requirements apply to large glass panels (e.g., 24
square feet or more). These cities reached a fair balance of benefit against
burden and give home designers a choice whether to have large glass panels.
Phase in the Ordinance. If residences are to be regulated, the ordinance should
be phased in over 5-10 years to give time for residential window manufacturing
to catch up and bird-collision studies to be completed.
Thank you for your consideration,
Kristin Sato
From:Bob Lenox
To:Council, City
Cc:board-plus@paloaltoairport.org; Swanson, Andrew; Luetgens, Michael; Christopher Burtrum
Subject:Bird Friendly Ordinance item 14, March 16, 2026
Date:Friday, March 13, 2026 9:05:14 PM
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on links.
Honorable Councilmembers,
This proposed ordinance must exempt the FAA Air Traffic Control Tower. Any obstruction to, or distortion of,
visibility could present a safety-of-flight concern. ATC Controllers require a clear view of the surrounding surface
and airspace in order to safely work aircraft. Please consider this before enacting this legislation.
Sincerely,
Bob Lenox, President
Palo Alto Airport Association
From:Claude Ezran
To:Council, City
Subject:Birdbrained idea: bird-friendly buildings in Palo Alto!
Date:Friday, March 13, 2026 6:12:04 PM
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!
Dear City Council Members,
I hope you will decisively quash this birdbrained idea of mandating that we now have bird-
friendly buildings in Palo Alto.
A little bird told me that the City of Palo Alto is not always paying close enough attention to
the unintended consequences of its well-intended decisions.
Over time the City has been piling-up regulations on top of regulations on top of
regulations. Each one of these regulations is, of course, well-intended. But if you step
back and, for once, take a bird’s eye view to consider the end result of all of this, you will
see a staggering pile of rules and regulations that substantially contributes to making
housing construction very expensive in Palo Alto. Each one of these regulations adds
complexity, costs, and delays to construction. And delays translate into additional costs: for
instance, if you borrow $3M at 6% to build a house in Palo Alto, each single day that you
lose waiting for a permit, a required report, an inspection, or the procurement of hard to find
materials mandated by the City, will cost you about $500.
Does the City ever look back at this gigantic regulatory mountain and consider retiring
some of these feel really good to pass but birdbrained and costly regulations that are not
that beneficial anymore? I doubt it does.
It does not require an eagle eye to see that that the City is winging it. Where is the study
showing the number of birds that actually die from building collisions each year in Palo
Alto? How does this compare to the number of bird deaths due to natural causes such as
birds being killed by predatory birds in Palo Alto? Are we making housing ever more
expensive in Palo Alto in order to save the lives of something like five birds per year? What
is the tradeoff?
This proposed ordinance and the recently passed dark sky ordinance are example of
extreme environmentalism gone haywire. How many astronomical observatories do we
have in Palo Alto? None, but we do have astronomical housing construction costs!
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Best regards,
Claude Ezran
From:Dashiell Leeds
To:Council, City
Cc:Clerk, City; James Eggers; Gita Dev; Sue Chow; advocate@scvas.org; director@scvas.org; Cha, Kelly;
kparkins@abcbirds.org
Subject:Support for March 16 Bird-Friendly Design Ordinance – Please Do Not Weaken Standards
Date:Friday, March 13, 2026 3:55:36 PM
Attachments:SCLP, SCVBA, ABC letter to Palo Alto re Bird Friendly Design.pdf
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Dear Mayor Veenker and Palo Alto Councilmembers,
The Santa Clara Valley Bird Alliance, the Sierra Club Loma Prieta Chapter and the American
Bird Conservancy support adoption of the Draft Bird-Friendly Design Ordinance adding
Section 18.40.280 to the Palo Alto Municipal Code as proposed in Attachment A.
Please read the attached letter for our full comments.
Sincerely,
Matthew Dodder
Executive Director
Santa Clara Valley Bird Alliance
Dashiell Leeds
Conservation Coordinator
Sierra Club Loma Prieta Chapter
Kaitlyn Parkins
Glass Collisions Program Coordinator
American Bird Conservancy
March 13, 2026
Subject: Support Bird-Friendly Design Ordinance – Please Do Not Weaken Standards
Dear Mayor Veenker and Palo Alto Councilmembers,
The Santa Clara Valley Bird Alliance, the Sierra Club Loma Prieta Chapter and the American Bird
Conservancy support adoption of the Draft Bird-Friendly Design Ordinance adding Section
18.40.280 to the Palo Alto Municipal Code as proposed in Attachment A.
Palo Alto residents consistently express strong support for protecting nature, biodiversity, and wildlife
habitat, as reflected in City policies such as the Comprehensive Plan and the Sustainability and Climate
Action Plan.
Scientific research shows that
● Bird populations in North America are declining, and the decline is accelerating,
● Collisions with glass and other human-made structures are a major driver of this decline,
● Collisions occur wherever birds are active, and
● In urban and suburban landscapes, most collisions occur at tree-canopy height, from ground level
to roughly 60 feet.
Protecting birds is particularly important in Palo Alto, where birds are abundant not only in the Baylands
and foothills, but also along riparian corridors and throughout the City’s urban forest, supporting large
numbers of migratory and resident birds.
The Draft Ordinance defines Bird Sensitive Areas in the Baylands and the foothills (east of Highway 101
and west of Foothill Expressway). Outside of these Bird Sensitive Areas, the ordinance does not apply to
any existing, modified or new portion of residential structures under 35 feet.
Routine window replacement does not automatically trigger bird-friendly treatment requirements unless
the glazing would otherwise trigger a building permit and falls into the hazard categories defined in the
ordinance. Therefore, the ordinance does not apply to most replacements of fenestration. We would have
preferred stronger requirements for new residential development and major remodels in order to avoid
creating new hazardous architectural elements, but we recognize that this ordinance has undergone
extensive review by Boards and Commissions and reflects substantial community input across multiple
commission and council terms. The result is a reasonable compromise, and we support adoption of the
draft ordinance as proposed.
Staff recommends that the City Council consider extending the 35-foot height exemption universally to
all development types. It is not clear whether this extension would remove the Bird Sensitive Area
qualifier.
We are strongly opposed to extending the 35-foot height exemption universally to all
development types as this would significantly weaken the ordinance and create a very low
benchmark for other jurisdictions to follow. As pointed out above, most collisions occur at
tree-canopy height, from ground level to roughly 60 feet.
Alternatively, Staff recommends expanding the allowance of films and decals for non-residential projects,
an option supported by local businesses in order to provide a more affordable compliance option when
specialized glazing is cost prohibitive.
If Council wishes to extend the allowance of films or decals to non-residential projects, we ask
council to direct the ordinance to limit these installations to products that are approved by the
American Bird Conservancy, and require the installation to be on the exterior-facing surface of
the glass, where they are most effective (https://abcbirds.org/products/).
Thank you for your leadership in protecting birds, biodiversity, and the natural character that residents
value in Palo Alto.
Sincerely,
Matthew Dodder
Executive Director
Santa Clara Valley Bird Alliance
Dashiell Leeds
Conservation Coordinator
Sierra Club Loma Prieta Chapter
Kaitlyn Parkins
Glass Collisions Program Coordinator
American Bird Conservancy
From:Victoria S. Ramirez
To:Council, City
Cc:Cha, Kelly; Molly Swenson (SHC)
Subject:SHC Letter of Concern Item 14 - Bird-Friendly Design (3/16/26)
Date:Friday, March 13, 2026 1:09:21 PM
Attachments:image001.png
Bird Safe Design Ordinance SHC Comment Letter - 3-11-26.pdf
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Dear Honorable Mayor and members of the City Council,
Attached you will find a letter from Stanford Health Care providing feedback and
expressing our concerns with Item 14 on the Monday, March 16 Council Meeting Agenda
– Bird-Friendly Design.
Please feel free to reach out if you have any questions.
Sincerely,
Victoria
VICTORIA S. RAMIREZ, MPA
she/her/hers
Director of State and Local Government Affairs
Stanford Health Care
Office of Government Affairs – Stanford University
1840 Embarcadero Road
Palo Alto, CA 94303
cell: 650-374-8729
vsramirez@stanford.edu
mailing address: 300 Pasteur Drive, M/C 5539, Stanford, CA 94305
Office of Government Affairs
Confidentiality notice: This communication and any attachments may contain confidential or privileged information for the use by the
designated recipient(s) named above. If you are not the intended recipient, you are hereby notified that you have received this
communication in error and that any review, disclosure, dissemination, distribution or copying of it or the attachments is strictly
prohibited. If you have received this communication in error, please contact me and destroy all copies of the communication and
attachments. Thank you.
March 13, 2026
Palo Alto City Council
City of Palo Alto
250 Hamilton Avenue
Palo Alto, CA 94301
Re: City Council Consideration of Proposed Bird-Friendly Design Ordinance
VIA EMAIL city.council@paloalto.gov; kelly.cha@paloalto.gov
Dear Mayor Veenker and Members of the City Council,
Stanford Medicine appreciates the opportunity to provide feedback on the current iteration of the
proposed Bird-Friendly Design Ordinance. As it relates to our medical campus, we have several concerns
with the proposal, particularly related to applicability, implementation costs, and user experience.
We were invited to attend the virtual outreach meetings with Planning staff in October 2025 and January
2026, and share the concerns voiced in the outreach meetings regarding the lack of formal studies
substantiating the need for this level of intervention and the negative impacts the bird-safe treatments
would have on building users’ experience. Based on the review of the most current information, the
proposed ordinance could negatively impact the design and costs of our future facilities.
We assert that the ordinance should be targeted to areas and situations in which bird collisions are most
likely to occur rather than being applied as a blanket rule across the entire city. Ordinances in other
jurisdictions, such as San Francisco and Oakland, are context-specific, requiring such measures for
buildings adjacent to open spaces that are of a certain size (at least 1-2 acres) and consist of wetlands,
open water, or heavy vegetation. For Palo Alto, applicability could be further informed for the local context
through a formal study of bird collisions in the City; we view this as a critical step in establishing place-
based policy.
Implementation of the ordinance as currently proposed would place a financial encumbrance on future
development. It has been noted by staff that implementation expenses for landowners and developers
have not been analyzed. This ordinance would demand the use of treated glass and/or significant façade
elements to break up large areas of glazing. Project budgets would need to be realigned to account for
these bird safe treatments. Based on recent cost estimates, using the existing glazing of Stanford
Hospital at 500 Pasteur Drive as a benchmark, the use of bird-safe glass etched with dots would increase
project glazing costs by approximately 18-20 percent. Implementation of the proposed requirements
would take away funds from other elements that may have a more proven benefit, considering the
necessity for bird-safe treatments in the City has not been firmly substantiated through a formal study.
Finally, the ordinance would dramatically impact the interior building experience for our staff, patients, and
visitors. Bird-friendly treatments significantly alter the experience of building users with highly visible lines
and dots on glazing and architectural elements that obstruct views. As demonstrated with Stanford
Hospital located at 500 Pasteur Drive, clear unobstructed views of the surroundings from our patient
spaces and other areas are a deliberate nod to biophilic design, shown in studies to improve overall
patient outcomes and reduce stress on healthcare workers. With these noted benefits, the intent would be
to carry this design language in the future development of our medical campus.
We appreciate your time and consideration of our concerns. We would like to request a continuation of
this item so that comments from us and others in the business community can be thoroughly assessed by
staff and City Council.
Please do not hesitate to contact me at vsramirez@stanford.edu if any questions arise.
Sincerely,
Victoria S. Ramirez Molly Swenson
Director of State and Local Government Affairs Director of Land Use & Licensing
Stanford Health Care Stanford Medicine
From:Mr. Shore
To:Council, City; Cha, Kelly
Cc:Armer, Jennifer; Lait, Jonathan; Shikada, Ed; Arellano, Caio
Subject:Bird-Friendly Design Standards Ordinance - March 16, 2026 - Agenda Item 14
Date:Friday, March 13, 2026 10:07:06 AM
Attachments:Palo Alto Airport Exemption - Bird-Friendly Design - 13 Mar 2026.pdf
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Dear Mayor Veenker, Members of City Council and Ms. Cha,
Please see the attached letter regarding the Proposed Bird-Friendly Design Standards
Ordinance (18.40.280).
Best regards,
Jeffrey Shore
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March 13, 2026
VIA E-MAIL [city.council@PaloAlto.gov and kelly.cha@paloalto.gov]
Mayor Veenker and Members of the City Council
City of Palo Alto
250 Hamilton Avenue
Palo Alto, California 94301
Kelly Cha
Senior Planner
City of Palo Alto
250 Hamilton Avenue
Palo Alto, CA 94301
Re: March 16, 2026 Agenda Item 14 — Bird-Friendly Design Ordinance (PAMC § 18.40.280)
Dear Mayor Veenker and Members of the City Council:
Please consider exempting the Palo Alto Airport (PAO), including the FAA-operated Air Traffic
Control Tower, from the Bird-Friendly Design ordinance. To avoid unintended comparisons, it is
suggested that the language of a PAO Bird-Friendly Design exemption should parallel the exemption
for “Lighting for Airport Operations” in PAMC § 18.40.250(d)(1)(C). See Ordinance No. 5692.
Add new section § 18.40.280(g)(6) to read as follows:
"(g) Exemptions. The following types of projects shall be exempt from Section
18.40.280(d):
. . .
. . .
(6) Glazing for Airport Operations. Nothing in this section shall be interpreted to
restrict, limit, or otherwise regulate glazing 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.
Respectfully submitted,
Jeffrey Shore
cc: Jonathan Lait, Director of Planning & Development Services
Jennifer Armer, Assistant Director of Planning & Development Services
Kelly Cha, Senior Planner
Ed Shikada, City Manager
Caio Arellano, Interim City Attorney
From:Mr. Shore
To:Council, City; Cha, Kelly
Cc:Armer, Jennifer; Lait, Jonathan; Shikada, Ed; Arellano, Caio; MFrancois@rutan.com; DLanferman@rutan.com
Subject:Bird-Friendly Design Standards Ordinance - March 16, 2026 - Agenda Item 14
Date:Wednesday, March 11, 2026 11:14:11 AM
Attachments:Edgewood Neighborhood Alliance Supplemental Letter - Bird-Friendly Design Ordinance - 11 Mar 2026.pdf
Edgewood Neighborhood Alliance Letter Regarding Bird-Friendly Design Ordinance - 02 Dec 2025.pdf
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Dear Mayor Veenker, Members of the City Council and Ms. Cha,
Please see the attached letter submitted on behalf of the Edgewood Neighborhood Alliance
regarding the Proposed Bird-Friendly Design Standards Ordinance (18.40.280). This letter
supplements our prior letter to the Planning & Transportation Commission, dated December 2,
2025, a copy of which is also attached to this email.
Best regards,
Jeffrey Shore
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March 11, 2026
VIA E-MAIL [city.council@PaloAlto.gov and kelly.cha@paloalto.gov]
Mayor Veenker and Members of the City Council
City of Palo Alto
250 Hamilton Avenue
Palo Alto, California 94301
Kelly Cha
Senior Planner
City of Palo Alto
250 Hamilton Avenue Palo Alto, CA 94301
Re: March 16, 2026 Agenda Item 14 — Bird-Friendly Design Ordinance (PAMC § 18.40.280)
Dear Mayor Veenker and Members of the City Council:
We, the Edgewood Neighborhood Alliance, are writing in reluctant and qualified support of
the proposed Bird-Friendly Design Ordinance (PAMC § 18.40.280) as recommended by the Planning
and Transportation Commission (“PTC”).
In so doing, we are compelled to note that, even with the PTC’s acknowledgement of the lack of
quantifiable data, two PTC members, including one member (James) who spent his entire career focused
on conservation at National Geographic, voted against the PTC’s motion and recommended against
adopting any ordinance because neither the local problem nor its solutions are sufficiently understood.
The truth is there are no local data that support this ordinance. In particular, there are no data of
bird collisions with windows, residential or commercial, in Palo Alto. In the absence of data, Palo Alto
should follow Sunnyvale and adopt guidelines for development. This is a solution in search of a
problem.1
I. The Comprehensive Plan Only Authorizes Guidelines
At most, the Comprehensive Plan authorizes guidelines, not mandatory zoning restrictions. The
Plan addresses bird-friendly building design at Policy L-6.3 and Program L6.3.1 — the only provisions
staff have cited as Comprehensive Plan authority across every staff report, board and commission
hearing over the past two years:
• Policy L-6.3: “Encourage bird-friendly design.”
• Program L6.3.1: “Develop guidelines for bird-friendly building design that minimizes hazards
for birds and reduces the potential for collisions.”
“Guidelines” are defined by the Comprehensive Plan as “[p]rovisions guiding the design of buildings
that are not mandatory but may be used by Staff, the City’s advisory boards and commissions and the
City Council in evaluating projects.” (“Design Guidelines,” p. 289, emphasis added.)
1 This letter supplements our prior letter to the PTC, dated December 2, 2025, a copy of which is attached. Considering the
PTC’s split-vote recommendation and its fundamental reservations with the ordinance, our prior letter remains highly
pertinent. Prior public comments on the Bird-Friendly Ordinance do not appear to have been compiled and included in
Council’s Packet for March 16, 2026.
Honorable Mayor and Members of the City Council
March 11, 2026
Under Government Code section 65860, a zoning ordinance that is inconsistent with the General
Plan is void. (Lesher Communications, Inc. v. City of Walnut Creek (1990) 52 Cal.3d 531, 540, 545-
546.) Where the Plan uses permissive language and authorizes a non-mandatory instrument, a
mandatory ordinance directly conflicts with that authorization. No other Comprehensive Plan provision
cures this defect. The draft ordinance’s own Section 1(A) recites that the Plan “included a policy
encouraging bird-friendly design and a program to develop guidelines,” then proceeds to enact
mandatory requirements with no consistency analysis. Under Lesher, that omission is fatal.
II. The Proposed Ordinance Would Burden Housing Development
We share the commitment to bird conservation, and we do not question the importance of
investigating bird-window collisions. But the ecological case for imposing mandatory residential
mitigations rests on extrapolations from generalized bird-window collision data, mostly from the East
coast, which have not been validated in the local context.2 Bird abundance decline is driven by myriad
contributing causes: habitat loss, predation, climate change, high-intensity agricultural activities, and
outdoor cats, among others.3 The relative contribution of residential window collisions to local bird
population trends, and the marginal benefit of specific residential glazing interventions, have not been
the subject of localized study in Palo Alto or the broader Peninsula. Before imposing costly mandatory
constraints on residential housing development based on these extrapolations, the Council should have a
clearer picture of what those constraints would accomplish.4
At scale, the compliance costs and project delays associated with the proposed mandatory
measures could materially frustrate housing production5 — a significant harm in a jurisdiction under
intense state housing pressure — while their avian ecological benefits in the residential context could
prove illusory. Those costs and delays stem from at least four compounding problems:
(i) No established market for residential bird-friendly glazing. The glazing specifications in
the ordinance were developed for commercial construction. There is no established consumer
market for residential bird-friendly glass and no off-the-shelf residential products that satisfy the
ordinance’s criteria.
2 Loss, Will, Loss, Marra, Bird–building collisions in the United States: Estimates of annual mortality and species
vulnerability, 2014 (the “Smithsonian Paper”), https://repository.si.edu/bitstream/handle/10088/25413/NZP_Marra_2014-
Birdbuilding_collisions_in_the_United_States_Estimates_of_annual_mortality_and_species_vulnerability.pdf?sequence=1&i
sAllowed=y. The authors reviewed eight prior studies with a total of 92,869 bird collisions and, applying extrapolation
mathematics, projected between 365 million and 985 million birds are killed per year by buildings in the U.S.
3 See, e.g., Leroy, Jarzyna, Kell, Acceleration hotspots of North American birds’ decline are associated with agriculture,
2026, https://www.science.org/doi/10.1126/science.ads0871. The authors found that about half of the 261 species analyzed
showed significant declines from 1987 to 2021, and a quarter showed accelerating declines. Hotspots of accelerating
abundance decline were located in regions with high-intensity agriculture (high cropland area, fertilizer use, or pesticide use).
4 The effort to adopt bird-friendly design regulations presupposes a problem with bird-window collisions in Palo Alto, but
there are no studies showing the nature or extent of the bird strike problem in Palo Alto. Crafting a suitable regulatory
framework with incomplete data is at best scattershot. (ARB Member Rosenberg: Feb. 15, 2024 Summary Minutes, p.19;
Feb 15, 2024 Video Timestamp 3:28:29; Jul 18, 2024 Summary Minutes, p.17; Jul 18, 2024 Video Timestamp 3:44:49; ARB
Member Baltay: Feb 15, 2024 Summary Minutes, p.19-20; Feb 15, 2024 Video Timestamp 3:34:25; Jul 18 Video Timestamp
3:54:47.)
5 Requiring bird-friendly glazing on residential buildings, particularly single-family homes, would be extremely onerous due
to its special-order-only availability. Consequently, it would frustrate efforts to increase housing production. (ARB Member
Hirsch: Jul 18, 2024 Summary Minutes p.18; Jul 18, 2024 Video Timestamp 3:55:32; ARB Member Adcock: Feb 15, 2024
Video Timestamp 3:31:57; Jul 18, 2024 Summary Minutes p.18; Jul 18, 2024 Video Timestamp 3:52:14; ARB Member
Baltay: Feb 15, 2024 Video Timestamp 3:34:25; ARB Member Rosenberg: Feb 15, 2024 Video Timestamp 3:28:29.)
Honorable Mayor and Members of the City Council
March 11, 2026
(ii) High cost of commercial-rated glazing customized for residential use. Adapting
commercial bird-safe glass to residential applications requires custom fabrication at costs
disproportionate to residential project economics, raising serious feasibility concerns.
(iii) Design constraints and aesthetic impacts. Commercial fritting patterns and glazing
specifications impose design and aesthetic constraints that conflict with residential architectural
norms6 and resident expectations.7
(iv) Environmental and sustainability concerns with non-permanent alternatives. Non-
permanent markers and films raise unresolved environmental and sustainability concerns
regarding adhesive materials and long-term durability that the ordinance does not address.
These are not hypothetical concerns. They reflect the real-world gap between criteria developed for
large-scale commercial construction and the requirements of residential development, a gap the
ordinance has not addressed and that cannot be closed simply by making commercial-grade criteria
mandatory.
III. A Practical Path Forward: Voluntary Guidelines
The Comprehensive Plan’s authorization of guidelines is the right instrument for this stage of the
City’s engagement with bird-friendly design in residential construction. In lieu of the proposed
ordinance that exempts most residential homes, we recommend the following course of action:
Adopt non-mandatory bird-friendly design guidelines. Direct staff to prepare and adopt
guidelines consistent with Program L6.3.1’s authorization. Those guidelines would be applicable
to all discretionary projects — commercial, institutional, and residential — through the City’s
architectural review process, reaching the substantial majority of new construction in Palo Alto.
Voluntary uptake under design review, combined with staff encouragement and public outreach,
can generate meaningful real-world experience with residential bird-safe design in this
community.
Obtain Palo Alto Bird Collision Studies. Partner with local environmental organizations to
monitor and evaluate the voluntary implementation of the guidelines over time — tracking which
measures are adopted, at what cost, with what design impacts, and with what observable effect
on bird collision rates in Palo Alto. This localized evidence base, rather than extrapolations from
generalized data, should inform any future decision about whether mandatory requirements are
warranted and, if so, what form they should take.
Once specific problematic buildings or building features are identified, adopt restrictions.
If the studies ultimately demonstrate that specific residential mitigations deliver meaningful
benefits at feasible cost, the Council will be in a position to put in place mandatory standards and
bring forward a revised ordinance grounded in locally validated, residentially appropriate
6 Glazing as a percentage of floor area for residential energy efficiency purposes is already calculated, but measuring glazing
as a percentage of each elevation in the context of residential development would add significant design costs, not to mention
Planning staff time required to check each calculation. (ARB Member Baltay: Jul 18, 2024 Summary Minutes p.19; Jul 18,
2024 Video Timestamp 4:05:27; ARB Member Adcock: Jul 18, 2024 Video Timestamp 4:05:43.)
7 In circumstances where the only outdoor views for residents are through their bedroom windows, such as in long-term care
developments, bird-friendly windows would not be a “pleasant” experience for those residents. (ARB Member Chen: Jul
18, 2024 Summary Minutes, p.18; Jul 18, 2024 Video Timestamp 3:56:12.)
Honorable Mayor and Members of the City Council
March 11, 2026
criteria. Coincident with a conforming amendment to the Comprehensive Plan, that ordinance
will be both legally defensible and substantively justified.
IV. Conclusion
Forcing a solution to a perceived problem without supporting data is not good stewardship of the
City. The increased housing development costs and delays would be material, as the Architectural
Review Board found. Nonetheless, if the Council desires to force a solution coincident with a
conforming amendment to the Comprehensive Plan, the PTC’s recommended approach, which excludes
most residential properties except portions over 35 feet high, is a reasonable pathway as it attempts to
balance burden and benefit in the absence of data.
Respectfully submitted,
EDGEWOOD NEIGHBORHOOD ALLIANCE
By, its representative,
Jeffrey Shore
cc: Matthew D. Francois, Rutan & Tucker, LLP
David Lanferman, Rutan & Tucker, LLP
Jonathan Lait, Director of Planning & Development Services
Jennifer Armer, Assistant Director of Planning & Development Services
Kelly Cha, Senior Planner
Ed Shikada, City Manager
Caio Arellano, Interim City Attorney
March 16, 2026 www.PaloAlto.gov
Bird-Friendly Design Ordinance
City Council
Kelly Cha, Senior Planner
2
Purpose
•Comprehensive Plan (2017)
•Policy L-6.3: Encourage bird-friendly design.
•Program L6.3.1: Develop guidelines for bird -friendly building design that
minimizes hazards for birds and reduces the potential for collisions.
•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.”
3
Public Meetings
•Architectural Review Board Study Sessions
⬧Focused discussion on the applicability, Bird -Friendly Treatment, and
exemptions for residential
•Planning and Transportation Commission Hearings
⬧Discussions focused on balancing broader protection with impacts on property
owners. Specific discussions on applicability, definition of Bird Sensitive Area,
and alternative compliance.
⬧Ultimately forwarded the draft specifically designed to reduce cost and
availability burdens, especially for residential development.
4
Community Engagement
•Public Comments.The written comments from multiple stakeholders have been
addressed throughout the entire process.
⬧Residents
⬧Local businesses
⬧Major developers
⬧Environmental advocates
•Focused Outreach Meetings with Palo Alto Businesses.
⬧Concerns over material costs, visual appeal impacting leases, and requested
allowances for films/decals for new nonresidential development.
5
Cost and Availability Concerns
•Availability and Project Timeline Delay
⬧No local stock and retailers generally unaware of products.
⬧No available residential market and require commercial -grade glazing purchase.
⬧No direct purchase possible and required to hire professionals to order.
⬧Special orders extend lead times in an already time -sensitive supply chain.
•Cost and Feasibility
⬧Higher commercial base rates plus additional $7 –$10 per s.f.
⬧Films are cheaper but labor -intensive and pose environmental concerns.
⬧Insect screens are cost effective but may not be architecturally compatible.
⬧Other cities essentially exempt single -family homes.
6
Draft Ordinance
•Applicability. New construction, major remodels, and Bird Hazard Installations.
•Bird Sensitive Area. East of Highway 101 and west of Foothill Expressway
•Bird-Friendly Design Requirements. Limit untreated glazing to a specific percentage
of each building elevation, with stricter limits for non-residential buildings and
those in a Bird Sensitive Area.
•Bird-Friendly Treatment Specifications. Permanent visual cues like dots or lines
spaced no more than 2 inches apart or use external features that break up the
glazing with no gaps larger than 9 inches. Non-permanent markers may be allowed
for residential.
7
Source: City of Berkeley
Sister Cities Café, Philadelphia
8
Google Campus in Mountain View
Source: City of Berkeley
9
Example Insect Screen from Home Depot
Metal Shutter House, New York City
The Grounds, Hobsonville Point, NZ
McDonald’s at Walt Disney World, Bay Lake, FL
10
Draft Ordinance (continued)
•Alternative Compliance. A report from a biologist or ornithologist proposing
alternative ways to comply with the intent of the ordinance.
•Exemptions. Historic structures, affordable housing, ADUs, and some commercial
first floor windows.
11
Additional Consideration – Exemption for Nonresidential
1.Exemption: Consider broadening 35-foot exemption to nonresidential structures
outside of the Bird Sensitive Area
•Currently applies only to residential structures outside of the Bird Sensitive Area
•Smaller-scale, nonresidential projects would have the same cost and supply
chain issues as small residential
•Provides relief on cost and supply issues with the specialized glazing, but
increases vulnerability for bird collisions as nonresidential development
typically uses larger glazing compared to residential development.
2.Alternatively, consider allowing films or decals for nonresidential structures
•Currently,films or decals are allowed only for residential development or the
residential portion of mixed -use development
12
Additional Consideration – Exemption for Airport
•Replace 18.40.280(h) with the following:
“California Building Code. Additional Provisions and Conflict Precedence. All
applicable windows, doors, or other features must comply with the requirements of
this section, in addition to the California Building Code, including the fire hazard
severity zone regulations in California Green Buildings Standards Code (CALGreen),
Fire Code, and applicable state or federal laws. In the event that Should a conflict
exist with the provisions of this section necessarily conflicts with the
aforementioned codes or state or federal laws, the standards in the applicable state
or federal laws and codes California Building Code shall prevail.”
•Add an exemption for Palo Alto Municipal Airport (18.40.280(g)(6)):
“Glazing that is necessary for airport safety or navigation in connection with
operations at the Palo Alto Municipal Airport.”
13
Next Steps
•Upon adoption of the draft ordinance:
•Second reading (consent item)
•Effective on the 31st day of the second reading
KELLY CHA
Senior Planner
Kelly.Cha@PaloAlto.gov
(650) 329-2155
BIRD-FRIENDLY DESIGN ORDINANCE
PaloAlto.Gov/BirdFriendlyDesign