Item 18 Public Comment — Palo Alto City Council, April 7, 2025

From: Marie-Jo Fremont
To: Council, City
Subject: Item 18: Please protect our city from light pollution - City Council Meeting April 7, 2025 Date: Monday, April 7, 2025 10:25:39 AM
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Dear City Council Members,
Other cities such as Brisbane and Cupertino have already adopted sensible lighting ordinances. Palo Alto also needs to adopt a strong and thoughtful lighting ordinance to reduce unnecessary energy consumption, improve the residents’ quality of life, and protect the natural habitats.

Please direct staff to:

Retain the current protection of waterways
Incorporate the Planning and Transportation Commission’s recommendations, including:

Making the ordinance applicable to all lighting fixtures and systems (new or replacements)
Implementing a “lights-out” curfew to prevent unnecessary nighttime lighting
Reducing the light trespass allowance to 0.1 foot-candle (not 0.5 foot- candle, which is so much brighter and unnecessary)
Thank you for your leadership and commitment to making our city healthier and more sustainable.

Marie-Jo Fremont
From: Clerk, City
To: Council, City
Cc: Clerk, City
Subject: FW: please vote for the dark skies
Date: Monday, April 7, 2025 8:43:56 AM
Attachments: image.png
Good morning City Council,

Forwarding the below public comment letter that was received to our inbox.

Thank you,
City Clerk’s Office

From: Rani Fischer <[email protected]>
Sent: Monday, April 7, 2025 8:37 AM
To: Clerk, City <[email protected]>
Cc: Shani Kleinhaus <[email protected]>
Subject: please vote for the dark skies

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Dear Mayor Lauing and Palo Alto City Council,

I am a resident of Sunnyvale with a cautionary tale. About five years ago, I had light from a half mile away pouring into my living room all night from the lights illuminating an office building for aesthetic purposes. I asked the City of Sunnyvale to stop them, but they couldn't because Sunnyvale's lighting ordinance did not apply to non-residential areas, and this light was from an office park. I wrote a letter to the Mercury News. https://edition.pagesuite.com/popovers/dynamic_article_popover.aspx? guid=55302a53-7199-4e48-b529-824f2aff25d9&appcode=SAN252&eguid=35e4c100- 7292-4da7-afaa-794640fd5fca&pnum=24#

It worked in that the Fortinet building lowered the angle of its light so that it did not affect me, and subsequently the birds flying overhead as much. I drove around last night and was happy to see that the Fortinet building had no facade lighting on it anymore.

Light pollution is a major problem, as you can see from this photograph of the South Bay I took from the top of Mt. Hamilton at 10pm two years ago. It's hard to change light bulbs, as funny as that sounds. It's easy to create an ordinance for future projects, but to make a dent in the current lighting situation takes energy and courage. The good thing about fighting light pollution is that the solutions are not expensive: changing to dimmer light bulbs, unscrewing every other light bulb on a street, or simply flipping the switch off.

If you create a strong ordinance that addresses current lighting, then other cities will follow because they look to Palo Alto as a leader.

Thank you for your dedication to the health and beauty of your city and for taking the time to consider dark skies.

Sincerely,
Rani Fischer
Chair of the Environmental Advocacy Committee
Santa Clara Valley Bird Alliance
From: Avroh Shah
To: Council, City
Subject: Item 18: Please protect our city from light pollution Date: Sunday, April 6, 2025 9:15:25 PM
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Dear Council,
I hope you are doing well. My name is Avroh Shah, and I am a member of the Palo Alto Student Climate Coalition (PASCC). I am writing to you in regards to agenda item #18 on the 4/7 City Council meeting. I have never been able to see the milky way in Palo Alto, and was hopeful that the dark sky ordinance would be strong enough for me to see some more stars.

However, after reading through it, I am doubtful.

I was concerned that the proposed ordinance only applies requirements to future buildings and major remodels, exempting current structures. As someone who has always deeply valued the accessible nature preserves that surround Palo Alto, I was also concerned by the sheer volume of light spillage that this ordinance would allow and I am worried about the impacts of light pollution in our nature preserves. I do support this ordinance, but I believe that it could be much, much stronger; specifically, it could apply towards current commercial buildings, and impose a lights-off curfew on them too.

Seeing the stars shouldn't be a luxury.

Warmly,
Avroh
From: Eileen McLaughlin
To: Lauing, Ed; Veenker, Vicki; Burt, Patrick; Lu, George; Lythcott-Haims, Julie; Reckdahl, Keith; Stone, Greer; Council, City
Cc: Carin High; Gail Raabe; Renzel, Emily; LaRiviere, Florence Subject: Comments, Dark Skies Ordinance, Citizens Committee to Complete the Refuge Date: Sunday, April 6, 2025 5:24:54 PM
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April 6, 2025
Mayor Ed Lauing
Members of the Palo Alto City Council
Transmitted by email
RE: Item 18, 04/07/2025, Dark Skies Ordinance
Dear Mayor Lauing and Members of Council:

The Citizens Committee to Complete the Refuge is pleased that you are considering a city-wide ordinance to implement Dark Skies priorities in Palo Alto. It is an action that will provide multiple benefits across the City including reduced disruption of circadian rhythms and health of both the community and wildlife.

Citizens Committee wishes to draw your attention to a significant omission.

Nowhere does the ordinance specify protection of wildlife in the ecological spaces on which they depend: creeks, parks and particularly the Baylands.

Parks provide eco-niche habitats throughout the city. Creeks do as well and are major wildlife corridors for nocturnal and fish species. The Baylands can be characterized as a treeless landscape naturally exposed only to moonlight.

Species native to that habitat include nocturnal foragers such as the endangered salt marsh harvest mouse. For them artificial illumination is deadly.

The City has substantial public service operations adjoining the Baylands. Each of these have lighting needs that must be provided. The ordinance reinforces that the City do so in accordance with city-wide illumination standards.

Unfortunately as the operations adjoin the Baylands and as the ordinance lacks any wildlife protection, Baylands wildlife will be put at particular risk.

Under Exemptions (Draft Ordinance, p.3, Section 2 (d)5) the airport is given broad authority to elect exemptions for “operations” sans any operation-specific designations. We agree that certain lighting requirements of airport operation are critical for providing safe landings, takeoffs, taxiing and to fulfill FAA requirements. But the airport services and its property serve numerous non- flight operations (maintenance, training, materials storage, vehicle parking) where more typical dark skies lighting standards can and should apply.

It is uniquely significant that the airport has shoreline wetlands within its own boundaries. Other than its Embarcadero Road frontage, it is surrounded by wetlands which include those present in the golf course. All of these wetlands serve shoreline wildlife nocturnally for foraging, nesting, roosting and mobility.

As it is for humans, wildlife circadian rhythms and essential behaviors are disrupted by artificial lighting which also introduces excessive exposure to nocturnal predators.

The airport, golf course, Geng Road recreation facilities, the RWF, the City facilities on East Bayshore Road and any other operations adjoining the Baylands need to implement wildlife-protective dark skies rules that eliminate, as much as possible, light trespass. Wetlands to be protected include the Duck Pond, Harbor Marsh, Baylands soughs, the Emily Renzel wetlands, the Palo Alto Flood Basin and those lands within the golf course and airport properties.

For the same reasons, the wildlife corridors and eco-niches of creeks and parks require like protection from light trespass.

Citizens Committee urges you to improve the Dark Skies Ordinance to include specific requirements to protect wildlife and their habitats in the City of Palo Alto.

Respectfully,
Eileen McLaughlin
Board Member
Citizens Committee to Complete the Refuge
CC: Carin High, Co-Chair, CCCR
Gail Raabe, Co-Chair, CCCR

From: Carl Thomsen
To: Council, City; Lauing, Ed
Subject: Proposed new lighting ordinance (18.40.250).

Date: Sunday, April 6, 2025 3:41:08 PM
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Dear Honorable Mayor and Members of the City Council,

I am writing to voice my objection to the new proposed lighting ordinance. I apologize for sending a second email on this topic but I reviewed the proposal in more detail and also went outside at night to observe the lighting situation.

I did not drive around the entire city but what was clear to me from the area I did observe was that the major source for light “pollution” in the residential neighborhoods was the streetlights. I didn’t see any support documents showing what the actual benefits this ordinance would be in terms of reduction in “light pollution”. If this doesn’t have any significant benefit other than a feel good “we’re saving the environment” then it shouldn’t be adopted. I would assume that the committee proposing this ordinance reviewed actual arial photos of Palo Alto at night to document the current source of the light pollution and this ordinance is a result of those reviews. If not, this is the proverbial “the emperor had no clothes”. I am quite sure that in terms of dark sky goals that the light from household windows, cars on the streets (including 101 adjacent to Palo Alto, streetlights, and buildings that keep there lights on all night for safety or other purposes contribute significantly more to light pollution than what this ordinance tries to address. Great headlines that Palo Alto has adopted the recommendations of the International Dark Light organization but no noticeable reduction on “light pollution”.

Another consideration is that the City of Palo Alto has a priority providing more housing. This is one more ordinance impacting the cost of building housing in the City. You may say this doesn’t have any or a minimal impact but it’s one more regulation to require review and compliance. Each “minor” impact on the housing cost adds up over time if not in actual material and build costs, then in design time, approval time and inspection time. Small incremental changes add up and discourage contractors from even wanting to build in an area with excessive codes.

Finally, I noted in the proposed ordinance that “public facilities may be granted for adjustments to the regulations in the ordinance to ensure efficient operation, maintenance, safety, and security”. For what reason would public facilities be excluded from an ordinance and private facilities and properties not be given the same exclusion.

Isn’t it equally important that private properties are granted exceptions for “efficient operation, maintenance, safety, and security”. Light pollution is light pollution whether it comes from a public or private building. This is a great example of government exempting themselves from laws that everyone else has to follow. Do as I say, not as I do. It’s a clear example of why citizens have lost confidence in the political system. Well, I haven’t lost confidence in our local leadership and hope you will seriously consider the issues I have raised.

For all of the above reasons I strongly recommend a no vote on this light pollution ordinance.

Sincerely,

Carl Thomsen
1701 Edgewood Drive
From: Annette Herz
To: Council, City
Subject: Please protect our city from light pollution
Date: Sunday, April 6, 2025 11:10:57 AM
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Dear Mayor Lauing and Palo Alto Councilmembers,
My Name is Annette Herz, I am a local resident and CA certified naturalist, who understands the link between our biodiversity and our own human well-being ! Please strengthen the proposed Dark Sky Ordinance !!!
Please ask city staff to
Apply the ordinance to newly installed or replacement lighting fixtures on existing structures, as recommended by the Planning Commission.

Set appropriate lights-out (curfew) requirements for outdoor lighting to prevent unnecessary night-time lighting.

Prohibit light spillage into homes, parks, and open spaces.

You have the power to help save us !
Thank you,
Annette
From: Darlene Yaplee
To: Council, City
Cc: Darlene E. Yaplee
Subject: Item 18: Please Protect Our City from Light Pollution Date: Sunday, April 6, 2025 9:45:09 AM
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i
Dear Mayor Lauing and Honorable Members of the City Council, I vividly remember years ago being on a plane where one side allowed smoking and the other did not—and on other flights, smokers were seated in the back while non-smokers were in front. These arrangements, though well-intentioned, failed to prevent smoke from drifting throughout the cabin. That experience has always stayed with me, and it’s a powerful analogy for light pollution: without meaningful, comprehensive protections, the effects spill over and harm everyone.

This is why it’s so important that Palo Alto adopts a strong lighting ordinance. To be effective, it must address the true nature of light pollution—how it spreads beyond property lines and affects neighborhoods, ecosystems, and the night sky.

Some have raised concerns about enforcement. But in many cases, including this one, the value of an ordinance lies in setting a clear standard and guiding behavior—even when daily enforcement is not the primary mechanism.

Neighboring cities like Brisbane and Cupertino have already adopted thoughtful lighting ordinances. Palo Alto should be a leader in this space as well—helping reduce unnecessary energy consumption, protect wildlife habitats, and preserve the quality of life for residents.

I urge the Council to:

Direct staff to incorporate the Planning and Transportation Commission’s recommendations, including:

Broad applicability to newly installed and replacement lighting fixtures and systems A meaningful “lights-out” (curfew) requirement to prevent unnecessary nighttime lighting A reduced light trespass allowance to 0.1 foot-candle
Ensure continued protection of our waterways, recognizing their ecological and community value Thank you for your consideration and your commitment to making Palo Alto a healthier, more sustainable city.

This message needs your attention
This is a personal email address.

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Sincerely,
Darlene Yaplee
From: Lyn Heideman
To: Council, City
Subject: Please strengthen the proposed “Ordinance Updating Lighting Standards” Date: Sunday, April 6, 2025 12:13:30 AM
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Dear Mayor Lauing and Palo Alto City Councilmembers,

I am so grateful that I moved to Palo Alto almost 20 years ago. And I am so proud of all that Palo Alto and the state of California have done to set a model for sustainable living and protecting the health of people, wildlife, and the environment.

I have read “Attachment A - Draft Ordinance Updating Lighting Standards (PAMC Section

18.40,” which was posted online in late March. I very much appreciate all that you’re doing and am writing to encourage you to strengthen the ordinance.

The ordinance should also apply to newly installed or replacement lighting fixtures on existing structures.
> Under the current ordinance, all properties are subject to a standard limiting light trespass to no more than 0.5 foot-candles at the property line. The proposed ordinance, however, applies this restriction only to new buildings, major remodels, and lighting systems that require a permit. The result? Existing properties would no longer be subject to any enforceable limits on light trespass.
> This change removes an important safeguard that currently protects all residents from excessive and disruptive lighting. Citywide light trespass limits help to ensure that all residents--regardless of when their home was built or last renovated--are protected from intrusive lighting.

To prevent unnecessary night-time lighting: (1) set appropriate lights-out requirements for outdoor lighting and (2) prohibit light spillage into homes, parks, and open spaces. > Let’s not lose sight of the reasons for the “dark skies ordinance” and ensure we meet those commitments: human health, nature and wildlife, reduced energy use, and restoring the beauty of the night.
> Studies show that artificial light at night disrupts sleep, hormone regulation, and overall health. It’s linked to increased risks of certain cancers, diabetes, heart disease, and mood disorders.
> Light pollution also disrupts the natural environment. Artificial light at night interferes with animal movement: for example, it disorients migrating birds, leading to exhaustion, disrupted navigation, even often deadly collisions with buildings. It also throws off the timing of key ecological processes and behaviors: it alters feeding, mating, and nesting behaviors; when migration or nesting starts; or when flowers bloom and pollinators emerge. > Light pollution wastes energy. Light pollution is contrary (1) to sound sustainability principles and (2) to the purpose of dark skies of using light only where/when it is needed and at the lowest level needed.
>.Light pollution steals the beauty of the night from us, of experiencing our world in darkness:
the stars, the moon, the sounds of night-time animals, the stillness.

Thank you very much for your consideration,
Lyn Heideman

From: Diane McCoy
To: Council, City
Subject: Please protect our city from light pollution
Date: Saturday, April 5, 2025 5:21:46 PM
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Dear Mayor Lauing and Palo Alto Council Members.

My name is Diane McCoy. I am a 47 year resident of Palo Alto. I taught Special Education and First Grade at El Carmelo School for 37 years.

Now retired, I am a volunteer for Environmental Volunteers, SCVBA, Avenidas and the PAHS PAWS program.

I am so grateful to have these opportunities in our city.

I also greatly and almost daily enjoy the Palo Alto Baylands, Byxbee Park, Renzel Wetlands, Foothills Park and my neighborhood park, Eleanor Pardee Park. I treasure these spaces.

Because these places, along with my neighborhood, is of such value I am writing to ask you to strengthen the proposed Dark Sky Ordinance:
-Please apply the ordinance to newly installed or replacement lighting fixtures on existing structures, as recommended by the Planning Commission. -Set appropriate lights-out (curfew) requirements for outdoor lighting to prevent unnecessary night-time lighting.
-Prohibit light spillage into homes, parks, and open spaces.

Thank you,
Diane McCoy
Greer Road, Palo Alto
From: Carl Thomsen
To: Council, City; Lauing, Ed
Subject: Proposed new lighting ordinance (18.40.250)
Date: Saturday, April 5, 2025 4:30:57 PM
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Dear Mayor and Members of the City Council,

I am writing to express my opposition to the
proposed new lighting ordinance (18.40.250).

Due to prior commitments, I will not be able to attend the Council meeting on Monday and express my concerns and objection to this proposal in person, so I am writing this email to document my opinion. I hadn’t seen anything about this new ordinance until just a few days ago.

We live along the San Francisquito Creek on Edgewood Drive with our fence directly adjacent to the creek. We have lighting in the front and back of our house that goes on at night to help protect us from a home or car robberies. We installed this lighting many years ago at the recommendation of the Palo Alto police department after we did have a home invasion. We regularly read about auto break-ins in our area. Fortunately, we have only had one auto break- in while our car was in our driveway. We have a front light and a front camera to deter potential criminals. Without the lighting, the camera would be pretty useless.

The proposal notes that many cities have adopted Dark Sky ordinances but there is no indication if these are urban or rural locations. I found 6 cities listed when I searched for cities with dark sky ordinances plus Malibu mentioned several times. What came up on my search was lots of information from the International Dark Sky Association on how to draft ordinances.

The fact that this ordinance only applies to new construction or major remodels seems like an easy way to get this passed without really considering the implications. It’s proverbial kicking the can down the road. If this is important to the city priorities, then why not have it apply to all existing dwellings? I would imagine there would be a lot more input from citizens of Palo Alto if that were the case.

I for one would much rather see the City of Palo Alto enforcing existing traffic laws than spending any time and money enforcing or mediating issues related to a Dark Sky initiative (not to mention the time and money already spent discussing and drafting this proposed ordinance). We are part of a large urban area, not a rural community. Let’s focus on urban issues like roads, sidewalks, robberies, speeding and safe streets to name a few. The City of Palo Alto has limited resources; let’s not spend any more time or money on this proposal.

I believe these proposed changes to the lighting ordinance will negatively impact our safety. I strongly urge a no vote on the proposal.

Sincerely,

Carl Thomsen
1701 Edgewood Drive

From: Tom Fountain
To: Council, City
Cc: Cha, Kelly
Subject: Opposition to Proposed Lighting Ordinance
Date: Saturday, April 5, 2025 1:13:27 PM
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Dear Mayor Lauing and Honorable City Council Members,
I am a resident of Palo Alto and am writing to register my objection to the proposed lighting ordinance scheduled for first reading on Monday, April 7, 2025.

While the intent behind the proposed ordinance is laudable in seeking to protect the environment through lighting standards, the ordinance as drafted is overly restrictive. I highlight the following:

Applicability of the ordinance: Highly restrictive lighting codes are most appropriate for sensitive ecosystems. The Architectural Resource Board (ARB) was correct in recommending we regulate areas differently based on the environment’s light sensitivity. Staff’s conclusion that such differentiation is “unnecessarily complicated” fails on its face. Even a cursory reading of our municipal codes shows that we frequently
differentiate based on hundreds of dimensions, certainly including the type of area. Highly restrictive code such as contained in this proposed ordinance are only applicable to the rural areas and not to the urbanized center. This ordinance should be applied to the area west of Junipero Serra Blvd as originally intended. If such differentiation is too “complicated” as claimed by Staff, I submit that at a minimum we should follow the ARB’s recommendation to differentiate between residential and commercial buildings, with the restrictions proposed in this ordinance most appropriate for commercial projects.

Insufficient security and safety protections: The proposed ordinance fails to adequately prioritize and protect the safety and security of Palo Alto residents in urbanized areas. The limitations on hours of operation, light output, requirements for motion sensors, and requirements that each controller be “fully programmable” are too restrictive to provide adequate safety for some residents facing acute threats. I have unfortunately been the frequent victim of crime, or had my house threatened, by the growing unhoused population residing next to my home. Effective lighting is my most effective method of safeguarding my property and family. Moreover, the inability to provide sufficient safety lighting around pools, walkways, and driveways (given hours, output, etc.) creates unfair personal risk. In a proposed ordinance that goes to great lengths to allow “special” conditions for even an airport, how is there no accommodation for a basic front porch light? Do we just expect that no child or guest will ever arrive late?
Unintended consequences: As acknowledged by Staff in the report, lighting ordinances are fraught with peril from unintended consequences. One such unintended consequences is the likely neighbor disputes. I’ll offer my own experience as an example, but having talked with many fellow residents, it is clear I am not alone. I have unfortunately faced countless complaints filed against my home by neighbors for everything from “we don’t like a [traditional] house style” to “I eyeballed the property line and the surveyor is wrong.” Having invested tens of thousands of dollars responding to these baseless claims, not a single one has ever been upheld. You don’t believe we will face constant neighbor complaints about a whole raft of perceived lighting violations? Responding to and investigating these complaints will be a waste of city resources. This is exactly why such an ordinance is too extreme for an urbanized area. The unintended consequences likely extend to many other situations. For instance, this ordinance appears to prohibit even temporary colored holiday lights. The proposed ordinance is too restrictive and too limiting for an urbanized setting.

Impact on housing development: We can likely all acknowledge our state (and region) faces a desperate need for greater housing production and better affordability. While Staff concludes the impact on development is low, I ask the City Council to consider the cumulative impact of our many similarly restrictive requirements already in effect (with yet more under consideration). Each and every “special” requirement unique to Palo Alto drives up the cost of living and drives down the availability of housing. Many “low” individual impacts cumulatively create a “high” impact on new housing production. Is there any wonder housing is so expensive and likely unaffordable for our children? In a time of such crisis, must we further reduce the availability and quality of housing in our area? Again, the immediate cure is simple. Apply the ordinance to the sensitive areas and/or limit it to commercial properties.

Technical failures: The proposed ordinance is incompatible with the city’s Comprehensive Plan. The Comprehensive Plan does not contemplate lighting restrictions for homes in areas east of Junipero Serra Boulevard. As advocated elsewhere throughout this letter, we should rescope this ordinance to the area contemplated originally by the Comprehensive Plan and where it applies most – the light sensitive areas in the foothills.

For the foregoing reasons and others cited in prior correspondence with the Planning & Transportation Committee and City Staff, I oppose the lighting ordinance update and ask you to redirect Staff to better address these issues.

Sincerely,
/s/
Tom Fountain
From: Susan Thomsen
To: Council, City; Lauing, Ed
Subject: Proposed “Dark Sky” Ordinances: Updating Section 18.40.250 (Lighting), Date: Saturday, April 5, 2025 9:17:11 AM
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i
Dear Honorable Mayor and Members of the City Council of Palo Alto,

It has just come to my attention via an email from a neighbor that a proposed new lighting ordinance will be before the Council on Monday, April 7, that will impact all residents of Palo Alto and that comprehensive input to the City of Palo has been given by the Santa Clara Valley Audubon Society and Sierra Club Loma Prieta Chapter. I do not believe the City of Palo Alto adequately informed me about the ordinance. It appears that members of the Audubon Society and Sierra Club must have been informed as they certainly were able to give a lot of input into the contents of the ordinance. It seems to me that as a resident of Palo Alto, at the very least, I should have received a mailer about this ordinance. I also believe a community meeting should have been called to get residents’ input as the updates to the lighting ordinance clearly would affect their properties. Because I only learned about this ordinance 3 days before the scheduled meeting, I am unable to attend the meeting because of a prior commitment.

I would like to go on record as opposing the proposed “Dark Sky” Ordinance Updating Section 18.40.250 because it protects wildlife at the expense of Palo Alto citizens. This past fall I wrote to you in opposition to creating a wildlife corridor in our backyard because we live along San Francisquito Creek and when we first moved into our house, a man entered our yard via the creek and proceeded to knock down our side door while my kids and I were getting ready for school and work. When I met eyes with the man when he was outside our glass door, he proceeded to break it down. Luckily, our deadbolt allowed us time to get out the front door, but the police told me the man was most likely after me. At the time the Palo Alto police would not come into our house until they had a dog unit with them. I will never forget that incident even though it occurred in 1981. At the time we were told that outside lighting, an alarm, and a dog were the best deterrents This message needs your attention
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to criminals and now the City of Palo Alto is proposing to control security lighting at the expense of the security of us citizens. I implore you to reconsider the proposed updating of the new lighting ordinance 18.40.250 requiring shielding of security lights and timers of 5 minutes on light sensors. We live in a neighborhood by the San Francisco Creek that needs all the deterrents possible to add to our feeling of safety including good lighting.

The safety of Palo Alto citizens should be your first priority.

Sincerely,

Susan Thomsen
1701 Edgewood Drive
Palo Alto, California

From: Dashiell Leeds
To: Council, City; Burt, Patrick; Lauing, Ed; Lu, George; Lythcott-Haims, Julie; Reckdahl, Keith; Stone, Greer; Veenker, Vicki
Cc: Clerk, City; City Mgr; James Eggers; Mike Ferreira; Gita Dev; [email protected]; Cha, Kelly; [email protected]
Subject: April 7 agenda item 18, Sierra Club and Santa Clara Valley Bird Alliance comments on the draft dark sky ordinace Date: Friday, April 4, 2025 2:26:55 PM
Attachments: April 7th Agenda item 18, SCVBA SCLP comments on Draft PA Dark Sky Letter.docx CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.

Dear Mayor Lauing and Palo Alto City Councilmembers,
We have supported Palo Alto in its efforts to create a Dark Sky ordinance by sharing research and model ordinance language with City staff, the Architectural Review Board and Planning & Transportation Commission. The Planning and Transportation Commissioners (PTC), in their October 30th motion, made an effort to recommend strong ordinance language that reflects the Five Principles for Responsible Outdoor Lighting, but the April 7th proposed ordinance has not incorporated some of the most critical PTC recommendations.

Our recommendations for Dark Sky applicability, lighting curfews, and light trespass thresholds are based on adopted Dark Sky policies in California, including ordinances from Cupertino, Malibu, and Brisbane. The draft ordinance to be heard by Los Altos City Council on April 8th 2025 also includes language consistent with these recommendations. Our recommendations are reflected in the October 30th PTC motion.

Please read the attached letter for our full recommendations.

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

Re: City Council April 7th agenda item 18: Sierra Club Loma Prieta Chapter and Santa Clara Valley Bird Alliance comments on the draft Dark Sky ordinance

Dear Mayor Lauing and Palo Alto City Councilmembers,

The Santa Clara Valley Bird Alliance and the Sierra Club Loma Prieta Chapter are organizations united by our shared commitment to the protection of the environment, nature, and open space.

Context
The introduction of LED lighting has induced vast improvements to energy consumption per lighting fixture (luminaire) and increased longevity of luminaires. These advances reduced the cost of lighting, resulting in more lighting overall. Furthermore, the spectrum of LED luminaires includes a high proportion of light in the blue (short wavelength) spectrum, which is harmful to human and environmental health.

To prevent and reduce light pollution through the proper application of quality outdoor electric lighting, DarkSky International developed the Five Principles for Responsible Outdoor Lighting1:

1 https://darksky.org/resources/guides-and-how-tos/lighting-principles/

We have supported Palo Alto in its efforts to create a Dark Sky ordinance by sharing research and model ordinance language with City staff, the Architectural Review Board and the Planning & Transportation Commission. The Planning and Transportation Commissioners (PTC), in their October 30th motion, made an effort to recommend strong ordinance language that reflects the Five Principles for Responsible Outdoor Lighting, but the April 7th proposed ordinance has not incorporated some of the most critical PTC recommendations.

Content of this letter
Our letter includes the following information, in order.

A. A list of items in the October 30th PTC motion
B. A summary of our recommended amendments to the April 7 draft ordinance C. A detailed background and analysis of each of our recommendations

A. PTC Motion of October 30, 2024 (passed 6:0:1 with Commissioner Hechtman absent):

● Reinstate the provision that would expand applicability to projects that only include new or replacement of existing luminaires: Rejected by staff.
● Add a hardship exception provision that could consider technical feasibility, consistency with a historic structure, or financial burden:

Rejected by staff.
● Change light trespass allowance from 0.5 to 0.1 foot candles (FC) throughout the ordinance: Rejected by staff.
● Reduce time limit on motion sensors from 10 minutes to five minutes:

Accepted by staff.
● Add definition terminology requested by Sierra Club based on suggested best practices. Accepted by staff.
● Recommend to City Council that further outreach be done at the time of implementation, informing residents of the new regulations; and that regulations for interior commercial lighting be considered in the future. ● In addition, the PTC approval included a city-wide lights out requirements that included existing lighting (curfew). Applicability narrowed by staff.

B. The following is a summary of the amendments we recommend to be made to the April 7th draft ordinance. Most of these recommendations mirror the PTC understandings and their motion of Oct 30, 2025.

1) Applicability
- Follow the PTC motion of October 30th to reinstate:
“(c)(3) Installation of new outdoor lighting, replacement of existing outdoor lighting fixtures, or changing the lighting type or system”. - Consistent with the October 30th PTC motion, develop a hardship exception provision that could consider technical feasibility or financial burden.

2) Curfew
- Reinstate the curfew language that was presented to the PTC on October 30th:
“(4)(A) Lighting Curfew. Unlike other provisions in this section, Lighting Curfew applies to all new and existing buildings and structures and luminaires, unless otherwise approved. All outdoor lighting shall be fully extinguished or be motion sensor operated by 10:00 p.m., two (2) hours after close of business, or when people are no longer present in exterior areas, whichever is later.”
- Note: The underlined language “and luminaires” was added by us (and was not originally in the October 30th motion) to include all outdoor lighting that is not exempt from this ordinance or regulated by state code in curfew requirements.

3) Light Trespass
- Implement the October 30th PTC motion to
“change the light trespass from 0.5 to 0.1 foot candles at every reference throughout the ordinance”

4) Protecting Streams and Baylands
- Ensure that no light trespass occurs into the Baylands Nature Preserve east of Highway 101.
- Retain the protections that the current municipal code provides to riparian ecosystems section 18.40.140 Stream Corridor Protection “(3) Requirements Within streamside review area
(g) Nighttime lighting shall be directed away from the riparian corridor of a stream.”
- If possible, include
“(4) Guidelines Within Streamside Review Area
(a) The distance between nighttime lighting and the riparian corridor of a stream should be maximized.”

5) Seasonal Lighting
Apply a unique curfew to Seasonal lighting (midnight - 8AM)

6) Findings and Declarations and Purpose Language

Add the Five Principles for Responsible Outdoor Lighting to the Findings and Declarations and Purpose sections of the ordinance.

C. A detailed breakdown of each of our recommended improvements

1. Applicability
The April 7th draft restricts the applicability of the ordinance to new construction, substantial remodels, and new luminaires requiring a building permit. Without applying the ordinance to new and replacement luminaires, Palo Alto cannot effectively reduce light pollution. Over time, old lighting fixtures are likely to be replaced with new non-compliant lighting fixtures, and many new fixtures may be added that do not require a permit. This is likely to increase light pollution in the city.

In addition, this is a departure from other recently adopted Dark Sky Ordinances such as Cupertino’s, Malibu’s and Brisbane’s ordinances, which include new and replacement luminaires. This is also a departure from the initial draft of Palo Alto’s ordinance (October 28th PTC draft), and a dismissal of the October 30th PTC motion.

August 28th PTC draft ordinance, Applicability language “(c) Applicability. For the purposes of this Section, except as otherwise provided in Subsection 18.40.250(3)(4)(A) below, the following projects shall comply with the outdoor lighting standards and guidelines set forth in this Section:
(1) All newly constructed structures and buildings
(2) Substantial Remodel, as defined in Section 16.14.070 of the Code, on existing
structures or buildings
(3) Installation of new outdoor lighting, replacement of existing outdoor lighting fixtures, or changing the lighting type or system” (emphasis added)

In the October 30th draft ordinance presented to PTC, Section (c) Applicability (3) was removed. However, PTC motioned during the October 30th meeting to reinstate that language.

The October 30th PTC Motion asked staff to
● Reinstate the original language of “Section (c) Applicability (3)” from the August 28th ordinance draft, which reads as follows: “(3) Installation of new outdoor lighting, replacement of existing outdoor lighting fixtures, or changing the lighting type or system, and
● Consider a “hardship exception provision” that could consider technical feasibility, consistency with a historic structure, or financial burden.

In the April 7th draft, staff has not reinstated section (c)(3) as requested. Instead, the draft April 7th ordinance proposes the following language:
“(3) New installation of outdoor luminaires requiring a building permit.”

Staff reasoning in rejecting the PTC motion (April 7th staff report) ● This is done “in order to reduce the enforcement and limit financial costs associated with these smaller projects”, and
● Staff considered an exception for projects facing significant financial impact from the new lighting requirements per PTC direction. However, staff determined that separating lighting costs from the entire construction cost or project valuation would be difficult for both applicants and staff responsible for verification.

Furthermore, the new standards do not apply to the replacement of existing outdoor lighting or changes to the lighting type or system, which was one of scenarios that led to the concerns of financial burdens. An exception for historic resources has been added to ensure that the new standards do not impair historical integrity.

Our response
● The Dark Sky ordinance, like many other regulations, does not require active enforcement. The ordinance simply provides a recourse to residents who are negatively impacted by light pollution. Furthermore, other cities that apply Dark Sky requirements to all new and replacement lighting, such as Cupertino and Brisbane, have not reported any issues with the enforcement of their standards.

● Applying Dark Sky standards to only permitted luminaires (as staff suggests in the April 7th draft) could increase the complexity of enforcement rather than reducing it. Residents cannot know whether they have recourse to complain when a light is bothering them, since they cannot know whether that nuisance lighting source was permitted. If a resident complains about nuisance lighting under the April 7th draft, staff may need to check to see whether the building in question has received any permits recently, and then check those permits to determine which fixtures were installed under that permit, and whether those fixtures are the ones causing the nuisance lighting from the complaint. The April 7th draft not only is less effective at reducing light pollution, it is also more difficult for residents to understand and is potentially more complicated for the City to enforce.

● Furthermore, if Dark Sky standards apply only to permitted lighting, then Palo Alto cannot hope to meaningfully reduce light pollution. Residents and businesses will continue to add new or replace existing fixtures with non- comforming luminaires. Unless the applicability extends to all lighting, the April 7th draft cannot stop existing property owners from installing flashing lights, strobe lights, or flood lights and other non-compliant luminaires that increase light pollution and light trespass into neighboring properties.

● Applying Dark Sky standards to all new and replacement luminaires (as was done in the October 30th PTC motion) creates a universal standard that can

more easily be understood by the public and by staff. For this reason, such recommended language is commonplace in adopted Dark Sky ordinances.

● Per the October 30th PTC motion, the City can consider including a hardship exception for existing structures to provide recourse for property owners seeking to replace existing lighting. This would cover edge-cases such as certain very old multi-family buildings that may require extensive re-wiring when replacing old luminaires with new Dark Sky compliant luminaires.

Proposed Amendment
- Consistent with the October 30th PTC motion, reinstate applicability language as motioned by the PTC on October 30th:
“(3) Installation of new outdoor lighting, replacement of existing outdoor lighting fixtures, or changing the lighting type or system” - Consistent with the October 30th PTC motion, develop a hardship exception provision for existing buildings that could consider technical feasibility or financial burden.

2. Curfew

The April 7th draft lighting curfew language stems from the applicability of the ordinance and therefore applies the lighting curfew only to new and replacement luminaires that were installed under a building permit.

This approach creates an inconsistent landscape where some properties remain illuminated all night long, while a relatively smaller number of properties must comply with curfew requirements. This is contrary to the Dark Sky principle of using light only when it is needed, will not achieve reductions in light pollution, and will not protect human residents or migratory birds. Furthermore, it could create confusion among residents and businesses.

This inconsistent curfew landscape could present an enforcement challenge to the City, since any complaints about non-compliance will require staff to check permits and identify which specific lighting fixtures received permits and therefore must comply with the curfew. This also presents an unclear situation for residents, who can’t know whether a nuisance source of lighting must comply with the ordinance. Previous versions of Palo Alto’s ordinance (the October 30th PTC draft) contained a curfew that specifically applied to all new and existing buildings and structures. This approach is easier for residents to understand, likely easier to enforce, and more effective at reducing light pollution.

At the October 30th PTC meeting, in response to Commissioners' questions, staff assured the PTC that curfew requirements apply to all new and existing buildings and structures (see the language in bold below).

Oct 30th Draft Language presented to PTC, Section “(e) Lighting Standards (4) Lighting Control (A) Lighting Curfew.
”Unlike other provisions in this section, Lighting Curfew applies to all new and existing buildings and structures, unless otherwise approved. All outdoor lighting shall be fully extinguished or be motion sensor operated by 10:00 p.m., two (2) hours after close of business, or when people are no longer present in exterior areas, whichever is later.”

This language was removed AFTER the PTC meeting, by staff in their April 7th draft. The curfew requirements in the April 7th draft are now restricted to the new applicability clause of the ordinance, limiting curfew requirements to only apply to the following:
(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) New installation of outdoor luminaires requiring a building permit.

April 7th Draft Language presented to City Council:

Section (e) Lighting Standards (4) Lighting Control (A) Lighting Curfew. “All outdoor lighting shall be fully extinguished or be motion sensor operated by 10:00 p.m., two hours after the close of business, or when people are no longer present in exterior areas, whichever is later.”

Staff reasoning and our responses
● Staff reasoning: The cost of enforcement is “unsupported based on existing staff levels.”
○ Our response: Active policing is not required or recommended. There is no support for an assumption that staff will receive many complaints, and if they do, that just proves that this ordinance is truly necessary. ● Staff reasoning: Requiring existing lighting fixtures to comply would set up an unrealistic expectation that all existing lighting would comply with the subject ordinance upon ordinance adoption.
○ Our response: Under the October 30th language, existing fixtures would need to comply with the lighting curfew, but not other provisions of the ordinance, because the curfew language has its own unique applicability clause that specifically applies to existing structures and buildings.

Furthermore, the curfew language allows for lights to remain on until two hours after the close of business, or until people are no longer present, whichever is later. Businesses that are open late or receive late night foot traffic would therefore have their operations unaffected by the curfew.

This sets a reasonable expectation for the public and makes the ordinance easy for them to understand.

○ In contrast, under the April 7th language, only permitted fixtures would need to comply with the curfew. This leads to situations where two identical fixtures, for two identical use cases, in two side-by-side locations, could have different curfew requirements, merely because one fixture was installed with a building permit and the other was not. This could make the ordinance incomprehensible to the public and prevent them from establishing any reasonable expectations regarding the lighting curfew.

● Staff reasoning: Mandatory motion sensors would be a cost burden for property owners, a lighting curfew without them would likely result in widespread non- compliance, increased neighbor disputes, and diminished public support for Dark Sky initiatives.
○ Our Response: Motion sensors are not mandatory in the ordinance.

There exist manual options as well as automatic timer devices that can be used instead of motion sensors. Motion sensors can cost $10-50.

Proposed Amendment
● Reinstate the curfew language that was presented to the PTC on October 30th, in section (e)(4) as follows:

“(A) Lighting Curfew. Unlike other provisions in this section, Lighting Curfew applies to all new and existing buildings and structures and luminaires, unless otherwise approved. All outdoor lighting shall be fully extinguished or be motion sensor operated by 10:00 p.m., two (2) hours after close of business, or when people are no longer present in exterior areas, whichever is later.”

- Note: The underlined language “and luminaires” was added by us (and was not originally in the October 30th motion) to include all outdoor lighting that is not exempt from this ordinance or regulated by state code in curfew requirements.

3. Light Trespass

In the October 30th PTC meeting, PTC motioned to “change the light trespass from

0.5 to 0.1 foot candles at every reference throughout the ordinance.” However, Staff did not change the 0.5 foot candles (FC) requirement. This allows for light many times brighter than the full moon to trespass into adjacent properties.

Staff reasoning

● “The maximum light trespass to an adjacent property is currently 0.5 foot- candle in the City’s lighting code. Staff recommends no change to this standard.”

● The PTC recommends 0.1 FC, which was adopted in nearby jurisdictions and reflects the Commission’s interest to minimize light spilling over to adjacent properties. While supporting this interest, staff is concerned that it sets up an unrealistic expectation of essentially no light spilling over to adjacent property and may result in increased complaints to the code enforcement program, taking staff from other priority cases. ● Moreover, the California Building and Safety Code stipulates a minimum illumination of 1 foot-candle for exit paths to ensure safe building egress; this standard will prevail where there is a conflict. Balancing the ordinance’s objectives with critical safety considerations, the maximum light trespass level was ultimately maintained at 0.5 foot-candle.”

Our response
● Cupertino uses a 0.1 FC standard, and Brisbane has a standard of zero trespass.
● 0.5 FC as an allowable light trespass number is as much as 25 times brighter than the light from a full moon (measured at .02 FC). The threshold for impacts to snowy plovers is 0.005 FC, so even 0.1 is impactful to the natural environment. ● The City must comply with the state building code, but it can and should reduce light trespass where lighting is not mandated by state law. If it results in many complaints to code enforcement, then the ordinance is doing exactly what it is intended to do, i.e., provide better livability and environmental health in Palo Alto.

4. Protecting streams and Baylands
Light at night devastates natural ecosystems. The existing ordinance recognizes this, and includes requirements and guidelines to reduce light impacts on streams. These protections are critical, yet they have been stripped from the language of the ordinance.

We are aware that a new steam protection ordinance is under development in Palo Alto, but until this new ordinance is adopted, the existing protections should remain in effect, and be expanded to protect other natural resources such as Baylands ecosystems.

Proposed Amendment
- Ensure that no light trespass occurs into the Baylands Nature Preserve east of Highway 101.
- Retain the protections that the current municipal code provides to riparian ecosystems section 18.40.140 Stream Corridor Protection “(3) Requirements Within streamside review area
Proposed Amendment
- Implement the October 30th PTC motion to “change the light trespass from 0.5 to 0.1 foot candles at every reference throughout the ordinance”.

(g) Nighttime lighting shall be directed away from the riparian corridor of a stream.”
- If possible, include the existing language:
“(4) Guidelines Within Streamside Review Area
(a) The distance between nighttime lighting and the riparian corridor of a stream should be maximized.”

5. Seasonal Lighting

The April 7th Draft Language exempts seasonal lighting during the period of October 15th through January 15th of each year from all of the requirements of the ordinance.

October 15th occurs during bird migration season.

With new holiday lighting innovations that increase lighting overall, we believe that protections for migratory birds and the Dark Sky is warranted. We recommend establishing a unique curfew for seasonal lighting, rather than exempting it from curfew requirements entirely.

Proposed Amendment
● Apply a unique curfew to Seasonal lighting (midnight - 8AM)

6. Add the Five Principles for Responsible Outdoor Lighting to the Findings and Declarations and Purpose sections of the ordinance.

These principles, from DarkSky International, are the basis for Dark Sky policy objectives, and should be included in the ordinance. As shown in the image on page 1 of this letter, these principles state that lighting should be useful, targeted, low level, controlled, and warm-colored.

Proposed Amendment
- Add the Five Principles for Responsible Outdoor Lighting to the Findings and Declarations and Purpose sections of the ordinance.

Thank you for your time and consideration.

Sincerely,

Shani Kleinhaus Dashiell Leeds Environmental Advocate Conservation Coordinator Santa Clara Valley Bird Alliance Sierra Club Loma Prieta Chapter

From: Daniel Hansen
To: Council, City; Lauing, Ed
Cc: Francois, Matthew; Lanferman, David; Lait, Jonathan; Armer, Jennifer; Shikada, Ed; Stump, Molly; Cha, Kelly Subject: Proposed Lighting Ordinance (18.40.250)
Date: Friday, April 4, 2025 1:15:20 PM
Attachments: Edgewood Neighbor Alliance Letter Regarding Dark Sky Ordinance.pdf CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.

Dear Honorable Mayor and Members of the City Council,

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

April 4, 2025
VIA E-MAIL [[email protected]; [email protected]] Honorable Mayor and Members of the City Council
City of Palo Alto
250 Hamilton Avenue
Palo Alto, CA 94301
Re: Proposed “Dark Sky” Ordinances: Updating Section 18.40.250 (Lighting), Amending Chapters 18.10, 18.12, 18.28, and Section 18.40.230 of Title 18 and New Outdoor Lighting Regulations (18.40.140)
Dear Honorable Mayor and Members of the Palo Alto City Council:

We, the Edgewood Neighborhood Alliance, are writing in objection to the proposed “Dark Sky” Ordinance updating Section 18.40.250 (Lighting), amending Chapters 18.10, 18.12, 18.28, and Section 18.40.230 of Title 18 and New Outdoor L ighting Regulations (18.40.140) as they apply to properties on Edgewood Drive.

We have four primary concerns:
 Safety and Security. The proposed ordinance does not sufficiently take into account the requirements for safety and security of Palo Alto res idents in the urbanized areas, particularly those residing along San Francisquito Creek.  Inconsistent with Comprehensive Plan. Application of the proposed ordinance to residents in the urbanized areas east of Junipero Serra Boulevard is inconsistent with the City’s Comprehensive Plan.
 Lack of Community Outreach. The City has failed to conduct adequate outreach to impacted residents, such as holding a community meeting and soliciting residential feedback by mailer. The Planning and Transportation Commission’s (PTC) recommended process to inform residents after implementation is backwards.  Unintended Consequences . The proposed ordinance will result in unintended consequences including creating a platform for neigh bors and environmental activists to harass homeowners and distracting police and code enforcement officers from meaningful duties.

I. Safety and Security
Edgewood Drive is Unique
The characteristics of San Francisquito Creek along Edgewood Drive are unique in that on the other side is East Palo Alto, which has no barriers to access to the creek, no meaningful creek

Honorable Mayor and Members of the City Council
April 4, 2025

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regulation, and limited resources for enforcement. There is literally nothing preventing people from entering the creek from the East Pal o Alto side. As a result, Palo Alto homeowners along Edgewood Drive, and the larger neighborhood, contend with – and have for years – homeless encampments, noise, trash, human waste, trespass, fire risk and crime.

Encampments and Crime.

It is unfortunate but San Francisquito Creek has become an area favored for encampments, likely due to the ease of access to the creek from the East Palo Alto side. Attached at Exhibit A are some of the emails and pictures sent to then Mayor Stone and others regarding encampments last summer and fall as well as pictures of other prior encampments. People living in these encampments chop down trees, pollute the creek with garbage and human waste, make noise (including screaming) and, most alarmingly, burn open fires. San Francisquito Creek in this area is bounded by eucalyptus trees, which are notoriously flammable, and thus our neighborhood is one errant ember away from a fire disaster . As you will see in the attached emails, then Mayor Stone acknowledged our “immediate safety concerns” and that this was an “urgent issue.”1 Just last week an encampment, this time on the Palo Alto side of San Francisquito Creek, was erected and later removed by Palo Alto police. We thank former Mayor Stone for his prompt response and directing the chief of police to respond.

Apart from encampments, the creekside properties on Edgewood Drive have been the subject of burglaries, trespass, loitering, etc., from the criminal element originating from the creek.

Many of our homes have been burglarized, trespassed and had items stolen. A few of the many police reports are attached at Exhibit B. These describe burglaries, attempted burglaries, prowlers and other events. Last October, Palo Alto police arrested a man for attempted murder for beating another man with a golf club in San Francisquito Creek.2 On October 29, 2024, a homeless man jumped a back fence of a creekside home on Edgewood Drive and tried to steal a container of fuel.

He was intercepted by the homeowner and then Palo Alto Police. Among other things, we have witnessed car burnings on Woodland Ave and routinely hear gunshots from the East Palo Alto side. Residents have found bullets in their swimming pools and yards.3 Palo Alto has previously recognized the unique circumstances of properties on Edgewood Drive. The City’s fence ordinance, for example, allows 10-foot fences on Edgewood along the creek for security and privacy. See PA Code 16.24.020(d). Also, the City implemented overnight parking restrictions in response to residents of the apartment complexes on Woodland Avenue in 1 Email dated October 2, 2024 from Greer Stone to Eliza Edelman. See Exhibit C. 2 See news article at https://www.cityofpaloalto.org/News-Articles/Police-Department/Police-Arrest-Suspect-in- Golf-Club-Attack
3 Palo Alto has not followed through on its plan to have a centralized crime mapping site, which would be helpful for our security. The Comprehensive Plan provides, “S1.4.1 Make data available to maintain an accurate, up to date, and complete real-time local crime mapping function to promote neighborhood safety.”

Honorable Mayor and Members of the City Council
April 4, 2025

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East Palo Alto crossing the Newell bridge and parking along Edgewood Drive and neighboring streets. See PA Code 10.51 et seq.4
Lighting is Essential for Safety and Security.

Lighting in our backyards and surrounding areas is the primary and key deterrent to crime and unhoused individuals jumping our fences. We need the ability to light our yards and fencing areas including the tops of fencing, and keep the lights on. We also need the ability to keep a front porch light on. Why the ordinance does not include a specific exception for porch lighting, like it does for “street numbers,” is baffling.5 Our children need to be able to see a door is clear of trouble from a distance at all times.

The proposed ordinance would only allow security lighting “when necessary to protect persons or property.” Who decides what is “necessary?” It would further require motion sensors on all security lighting and limit the amount of light that can shine over fences. Motion sensors, however, have limited reach, do not always work, can be tricked or bypassed and can be tripped by animals or birds, creating false alarms . A limit of 0.5 candles of “light trespass” over a fence is insufficient (as well as confusing as no one knows what 0.5 candles means ). Our primary security fencing faces East Palo Alto for which there are no adjacent properties. Thus light extending over that fencing in the interests of safety should not be an issue. And our neighbors understand and appreciate the need for lighting of rear and side yards and porches.

Edgewood Drive Homes Should be Exempt.

The homes along Edgewood Drive should be exempt from the proposed ordinance due to their unique circumstances and safety requirements or, at minimum, be exempt from the limitations on security, timing and side lighting. Safety is the City’s paramount duty to its residents and properties along Edgewood are particularly vulnerable.

II. The Proposed Ordinance is Inconsistent with the Comprehensive Plan.

The Comprehensive Plan does not contemplate adopting “dark sky” ordinances to urbanized residential homes. Policy N -7.5, on which the staff and environmental groups rely, states in its entirety the following:

Policy N-7.5 Encourage energy efficient lighting that protects dark skies and promotes energy conservation by minimizing light and glare from development while ensuring public health and safety.

Policy N-7.5 says to “encourage energy efficient lighting.” There is no authorization to implement ordinances or restrict development. Consistent with this policy, the City should look 4 Non-permitted cars are still regularly parked along Edgewood at night because the City’s police enforcement of the parking ordinance is virtually non-existent.
5 The exception in 18.40.250(e)(4)(D)(i) for “building entrances” applies only for timing control and is unclear if it includes homes and porches.

Honorable Mayor and Members of the City Council
April 4, 2025

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for ways to encourage use of energy efficient lighting (such a tax rebates), not compel it by regulation.

The other reference from the Comprehensive Plan cited by staff is Program N7.5.1. This Program states that “ All development in the foothill portion of the Planning Area (i.e., above Junipero Serra Boulevard) should visually blend in with its surroundings and minimize impacts to the natural environment . As such, development projects should: … Include exterior lighting that is low-intensity and shielded from view.”
Thus, the most the Comprehensive Plan contemplates for building restrictions on lighting is for development west of Junipero Serra Boulevard.

Application of the proposed ordinance to the urbanized areas east of Junipero Serra is inconsistent with the Comprehensive Plan and thus the City lacks authority to adopt it. It is black- letter law that a city’s adoption of zoning and development ordinances must be consistent with its comprehensive plan.6
Limiting lighting in residential housing is not a top priority for the City Council. City staff readily admit that the proposed lighting ordnance “does not directly relate to any of the key actions of the Palo Alto Sustainability Climate Action Plan (S/CAP).” The City has bigger issues to tackle, such as housing, encampments and safety.

III. Lack of Community Outreach.

The City has not conducted adequate outreach to potentially impacted residents. The PTC recommended that community outreach be conducted after implementation of the ordinance. That is absurd and backwards. Community outreach and input should be solicited before the ordinance is adopted, not after it is implemented.

It is troubling that City staff directly solicited input from the Audubon Society and Sierra Club on the ordinance, 7 but did not do so from Palo Alto residents. City staff did not send out written mailers of the proposed ordinance or hold community meetings with residents, like it has with the proposed “creek corridor” ordinance. All staff did was post it under a usual agenda item 6 “The propriety of virtually any local decision affecting land use and development depends upon consistency with the applicable general plan and its elements.” (Citizens of Goleta Valley v. Board of Supervisors (1990) 52 Cal.3d 553, 570.) A city’s general plan is effectively the “constitution for future development” in the community, and any zoning ordinance or other subordinate land use action must be consistent with the general plan. (Lesher Communications, Inc. v City of Walnut Creek (1990) 52 Cal.3d 531, 540, 545-546 [zoning amendment that was inconsistent with the general plan adjudged to be void ab initio].) In order to be deemed “consistent,” the zone change must actually be “compatible with the objectives, policies, general land uses, and programs specified in the general plan.” (Napa Citizens for Honest Government v. Napa County Board of Supervisors (2001) 91 Cal.App.4th 342, 378-79 [county abused its discretion in adopting a specific plan that permitted development without “definite affirmative commitments to mitigate” impacts to traffic and housing contrary to policies and objectives set forth in its general plan].)
7 Staff writes in the mini-packet, “In addition, staff have engaged with representatives from the Santa Clara Valley Audubon Society and Sierra Club Loma Prieta Chapter to solicit their input on the proposed ordinances.”

Honorable Mayor and Members of the City Council
April 4, 2025

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on the City’s byzantine website and trust that residents are savvy enough to find it and understand how it impacts them. Then, to dampen impact, residents are limited to a 3 -minute statement at a public hearing. Residents should get equal or more access to staff and floor time than the Audubon Society and Seirra Club. The process follow by staff is clearly inadequate given the circumstances.

Further, t he Architectural Review Board (ARB) recommended against extending the proposed lighting ordinance to residential homes. The ARB got it right. Why the PTC chose to ignore the ARB’s recommendation is unclear and unsupported.

In the interest of fairness and transparency, and in view of the scope of the proposed ordinance and the rejection by the ARB, the City Council should direct staff to solicit residential input, including sending a direct mailer and holding community meetings, and have the ordinance reconsidered by the newly constituted PTC.

We witnessed the same overreach by the PTC last October with respect to the proposed “Bird-Friendly Ordinance,” which is scheduled to be considered by the Council in May. The ARB unanimously rejected application of the ordinance to residential homes because of the burden and expense on homeowners and lack of available commercially made windows. The PTC, however, ignored the ARB’s position and recommended extension of the ordinance to residential properties within 300 feet of a natural creek. The PTC did this in response to the request of Ms. Kleinh aus of the Audubon Society (who was sitting with City staff and invited to speak by a commissioner), and without any commissioner inviting, hearing from or considering homeowners’ concerns and without any scientific evidence that the ordinance would protec t species of birds living in Palo Alto.

We, along with our lawyers at Rutan & Tucker, will be responding to the proposed Bird - Friendly Ordinance in due course. We trust that in the meantime the City Council will reject the PTC’s misdirected recommendations here and revert the proposed lighting ordinance for further and direct community input and reconsideration by the PTC.

IV. Unintended Consequences.

The proposed ordinance has unintended consequences that require it be reconsidered and streamlined. Apart from putting our families are risk, the ordinance with its detailed and technical specifics will create a platform for neighbors and environmental ac tivists to harass homeowners and distract police and code enforcement officers from their meaningful duties.

If the proposed ordinance is adopted, it is easy to envision people or groups complaining to the city police, fire department and code enforceme nt personnel. They could also use this ordinance as a proxy to harass each other. Here are some examples:
- When abutting residential use, “no spillover of lighting to adjacent properties shall be allowed.” Complaint: the light is spilling over.

Honorable Mayor and Members of the City Council
April 4, 2025

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- All light sources “shall have a correlated color temperature of 2,700 Kelvin or less .” Complaint: the color temperature of a light is too high. - No more than “420 lumens shall be allowed for permitted non -shielded outdoor lighting.” Complaint: the light is too intense.
- The “maximum outdoor light intensity on a site shall not exceed an average value of 5 foot-candles.” Complaint: the light density is too high. - Low voltage luminaires “may not direct light towards the public right -of-way.” Complaint: the plant light is directed at the sidewalk. - Security lighting may be provided “when necessary to protect people or property.” Complaint: the lighting is unnecessary.
- Security lighting shall “extinguish after no more than five minutes” after activati on.

Complaint: the lighting stays on too long.
- Security lighting cannot “trespass above 0.5 foot -candle onto an adjacent or nearby property.” Complaint: the light trespasses too much into other property.

The Council should think carefully before tur ning the neighborhood into to a complaint factory.

An ordinance of this nature should be introduced slowly over an extended period of time to avoid unintended consequences. It is clear from the language that the draft ordinance was intended to apply to commercial buildings, not residential homes. The City should start with commercial buildings and parking lots and move to residential properties later. This will allow the City and staff time to monitor its impact on safety and use of enforcement resources and benefits versus burdens.

If the proposed ordinance proceeds, it should apply only to new construction. If it applies to existing homes or replacement lights, the impact to residents would be immense, expensive and confusing.

Sincerely,

EDGEWOOD NEIGHBORHOOD ALLIANCE
By, its representative,
_____________________
Daniel Hansen

Honorable Mayor and Members of the City Council
April 4, 2025

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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
Molly Stump, City Attorney

Honorable Mayor and Members of the City Council
April 4, 2025

Page 8 ends

Exhibit A
Emails and Pictures Regarding Encampments

1 From:

Sent: Sunday, October 27, 2024 11:20 AM
To: Code Enforcement <[email protected]>; Lenin Melgar <[email protected]>; Kevin Lewis <[email protected]>; Fatima Khan <[email protected]>; Diana Tran <[email protected]>; Jay Farr <[email protected]>; Clean City <[email protected]>; Darryl Hall <[email protected]> Cc:

Subject: Re: Woodlawn UPDATE
Hello Darryl,
I'm sorry to bother you on a Sunday, but there were some loud screaming of woman crying going on around Woodland area of the creek bank. A man yelling at "Karvina" (was what we can capture).

There seems to be something violent going on there. We started hearing loud yellin g (fighting?) voices between a man and a woman during the day yesterday. And this morning (a few minutes ago), clearly crying sobbing sound is heard. We cannot see what is going on due to branches obscuring, and people are probably under the tarp.

Would you or your folks be able to help this woman
soon?

On Monday, August 5, 2024 at 11:20:53 AM PDT, Darryl Hall <[email protected]> wrote:

Good morning team
I’m at the Woodland Ave.

A male client responded
The client refused to come out and talk to me and said he needs no service Darryl
Sent from iPhone
Darryl Hall
650-730-4840
[email protected]

1 From: Stone, Greer <[email protected]>
Sent: Thursday, October 10, 2024 7:31 PM
To:

Cc: Lenin Melgar < [email protected]>; Kevin Lewis <[email protected]>;

Subject: Re: Creek Encampment s Endangering PA Home Owners Good evening, everyone.

Thank you for bringing this serious issue to my attention and for sharing the video. Since receiving this information yesterday, I’ve been actively reaching out to staff and other officials to understand the jurisdictional complexities and coordinate an effective response.

After speaking with the SFCJPA Executive Director, Palo Alto’s Fire and Police Chiefs, and the Mayor of East Palo Al
to, it’s clear the encampment falls under EPA’s jurisdiction. However, just because EPA has jurisdiction doesn’t mean Palo Alto shouldn’t do everything we can to help mitigate the risks to our residents and your properties.

I spoke with the EPA Mayor again this evening, and we both agreed that this is an issue our cities should tackle together, with EPA taking the lead given the encampment is in their jurisdiction. We’re currently organizing a meeting between our city managers and police chiefs to explore how Palo Alto can assist in clearing these encampments. I’m optimistic that, with the necessary political will, we can address this issue promptly.

Thank you again for bringing this to my attention. I’m committed to working with all our partners to resolve this and will keep you updated on our progress.

Best,
Greer
Greer Stone
Mayor
City of Palo Alto
Phone: 650-575-0405
E-mail: [email protected]
www.cityofpaloalto.org

1 From:

Sent: Tuesday, October 8, 2024 8:49 PM
To: Stone, Greer <[email protected]>
Cc: Shikada, Ed <[email protected]>; Nose, Kiely <[email protected]>; Lenin Melgar <[email protected]>; Kevin Lewis <[email protected]>; Subject: Re: Creek Encampments Endangering PA Home Owners Update: as we’ve feared for months, and have been warning about, tonight there is a FIRE in the creek behind our homes! The Menlo Park Fire Department is responding now. Please act with urgency to clear the encampment.

1 From: Stone, Greer <[email protected]>
Sent: Thursday, October 3, 2024 9:38 AM
To:

Thank you for that additional information and context. That’s helpful information to have while I speak with city staff members and our regional partners.

I had a follow up discussion with Margaret Bruce yesterday, she’s the executive director of the SFCJPA, a regional body that I vice chair. We recently facilitated a Homeless Encampments Working Group. That group has met twice to discuss various issues associated with homeless encampments. Going forward, it will be a standing item on the regular monthly managers/executives meeting to ensure opportunities to share best practices and information.The issues the group has discussed so far are practices and policies regarding clearing homeless encampments and sharing maps to help figure out jurisdictions when homeless encampments are reported.

My understanding of the jurisdictional issue here is complicated. Most of the creek is in private ownership, but in some places, there are easements for flood control maintenance, and there are some county or city-owned areas as well. It's a complex quilt of jurisdictions.

I will continue to engage in discussions with staff and regional partners and I will update you as I get more information.

Looking into funding opportunities from the state is also a possibility, given that Governor Newsom announced that he will be providing $1 billion in Encampment Resolution funding. I will look into possibilities of Palo Alto seeking some of those funds to help with this growing concern.

Be well,
Greer
Greer Stone
Mayor
City of Palo Alto
Phone: 650-575-0405
E-mail: [email protected]
www.cityofpaloalto.org

2 On Oct 2, 2024, at 9:54 PM, wrote:

Dear Mayor Stone,
Thank you for your thoughtful and considered response. We are very encouraged to hear that you will
make it a priority to follow up with all the agencies involved to develop a collaborative plan that restores safety to our neighborhood. This is the type of attention and action we've been asking for a very long time, and we so appreciate your understanding and willingness to engage and help.

To aid in your effort, the other people that we've been in contact with that are acutely aware of the situation besides Kevin Lewis (who was the point person working with the EPA Mayor and City Attorney) are Diana Tran and Fatima Khan (Environmental Services) and Jay Farr (Public Works Supervisor), as well as Lenin Melger, Code Enforcement Officer.

As to offering services to the campers - the team sent Daryl Hall from LifeMoves on 8/5/2024 down into the creek to talk to the person living in the encampment (there are more now) and offer him aid and services. He reported that, "they male client refused to come out and talk to me and said that he needs no services." I believe this was one of several attempts made to offer aid.

I understand that Governor Newsome has acknowledged the problem our state is facing with regard to encampments and has offered funds to local municipalities to take action and clean up encampments like this one. Thank you again for making this a priority and being willing to work to address this important issue.

Best regards,

1 From: Stone, Greer <[email protected]>
Sent: Wednesday, October 2, 2024 2:52 PM
To:

Cc: Shikada, Ed <[email protected]>; Nose, Kiely <[email protected]>; Lenin Mel gar <[email protected]>; Kevin Lewis <[email protected]>; Subject: Re: Creek Encampments Endangering PA Home Owners Dear ,
Thank you for taking the time to share your concerns, and I truly appreciate the care and detail you've provided in your email. I understand the deep connection you have to Palo Alto as a lifelong resident and the seriousness of the situation affecting your family, neighbors, and community . The safety and well-
being of our residents are top priorities, and I hear your concerns about the encampments in the creekbed behind your home.

Homelessness is a complex and challenging issue that requires coordination across multiple agencies and jurisdictions. As you’ve described, the creek lies between Palo Alto and East Palo Alto, which means that cooperation between our two cities, along with the Santa Clara Valley Water District and other regional agencies, is crucial to address this problem effectively.

I understand your frustration about the lack of progress and the buck-passing that you’ve encountered. It is unacceptable for residents to feel unsafe in their own homes and neighborhoods, and it is essential that we take action. I will personally ensure that this issue is raised at the appropriate level with both Palo Alto and East Palo Alto officials, as well as the relevant departments involved.

I understand you’ve already had contact with Kevin Lewis, Public Works Supervisor in East Palo Alto, and I will make sure that we follow up with him to understand the scope of their efforts and to coordinate Palo Alto’s role in resolving this situation. I will also request that our Public Safety and Public Works teams coordinate closely with East Palo Alto officials to ensure a comprehensive and sustainable response that prevents further encampments from being set up in this area.

In addition to addressing the immediate safety concerns, we will also be mindful of finding longer-term solutions for the broader issue of homelessness in our region. It’s important that we not only focus on enforcement but also support services and resources for those who need help in transitioning out of homelessness.

Thank you again for bringing this urgent issue to our attention. I will make it a priority to follow up with all the agencies involved to develop a collaborative plan that restores safety to your neighborhood. I will keep you and your neighbors informed of any developments as we work to resolve this.

2 Please don’t hesitate to reach out if you have any further concerns or additional information that might assist in this process.

Be well,
Greer
Greer Stone
Mayor
City of Palo Alto
Phone: 650-575-0405
E-mail: [email protected]
www.cityofpaloalto.org

1 From:

Sent: Wednesday, October 2, 2024 12:38 PM
To: [email protected]; [email protected]; [email protected] Cc: Lenin Melgar <[email protected]>; Kevin Lewis <[email protected]>;

Subject: Creek Encampment p hotos
Here are the photos taken today of the encampments behind our home at Edgewood Dr, in Palo Alto. It is in front of
Woodland Ave, East Palo Alto. Unfortunately the video is too large to send. I'm happy to show you in person if you'd like to come over and see for yourselves.

Best regards,

2 3

4 This email has been scanned for spam and viruses. Click here to report this email as spam.

1 From:

Sent: Wednesday, October 2, 2024 12:24 PM
To: [email protected]; [email protected]; [email protected] Cc: Lenin Melgar <[email protected]>; Kevin Lewis <[email protected]>; Subject: Creek Encampments Endangering PA Home Owners
Dear Mayor Stone and City Manager Shikada,
My name is , and I am a life-long Palo Alto resident. I was born at Stanford Hospital, was raised in Palo Alto on Greenwood Ave., and after going away for college and starting a family of my own moved back
to raise my own family here. ,
and my family and I live up the street on Edgewood Drive. It's been a lifelong dream of mine to be able to give my children the privilege of growing up in Palo Alto - such a SAFE, open-minded, educated community. However over the past few years, Palo Alto doesn't feel like the idyllic place I grew up in. We live on Edgewood Drive, and our backyard butts up onto the creek. In the past few years, a group of unhoused individuals have taken over the creekbed behind our house and my neighbors and have set up encampments that are dangerous and threatening our homes and safety. They have gone largely unchallenged. As you can see from the photos and videos I took just this morning, they have created elaborate structures-trashed the creekbed, have propane tanks and fires regularly, throw trash and litter and feces into the creek, and often have loud arguments and fights that make my children fearful and come inside, unable to feel safe in our own backyard. Several of our homes - including mine - have been broken into an burglarized from people gaining access to our homes through the creek. Our neighbor this summer was harassed and physically threatened by the creek dwellers behind their home. WE NEED

YOUR HELP TO CLEAN UP THE CREEK, AND ERADICATE THE ENCAMPMENTS THAT ARE MAKING US UNSAFE.

The encampment I'm writing about is in the creek behind my home at:

Edgewood Dr, Palo Alto
and in the creek in front of:

Woodland Ave, East Palo Alto
We have been reaching out to agencies in Palo Alto (Public Works, code enforcement, Police), and East Palo Alto (public works, police, code enforcement) and the Sillicon Valley Water District, and all anyone ever does is PASS THE BUCK.

The group we've been in the most contact with that actually returned my calls and has observed the situation first hand on the ground is Kevin Lewis, Public Works Supervisor, East Palo Alto. At one point over the summer, he told me they were contacting a company to come through and clean out the encampments. He said it is expensive and they could only afford to do it once, and will need help and cooperation from Palo Alto moving forward. I'm BEGGING you to please work together to clean up the encampments, and return a sense of safety to residents on BOTH sides of the creek. We are unable to

2 take care of this pressing issue ourselves as citizens and are relying on our government officials to intervene and take care of pressing safety concerns when they occur for their constituents. Please, please take action.

I have copied my concerned neighbors that also have encampments in the creek behind their homes, as we are ALL invested in seeing progress on this issue.

Thank you in advance for your help.

Best regards,

This email has been scanned for spam and viruses. Click here to report this email as spam.

1 From: Tess Byler <tbyler@sfc
jpa.org>
To:

Cc: Denean Ni <[email protected]>; Miyko Harris-Parker <[email protected]>; Margaret Bruce <[email protected]> Sent: Monday, August 12, 2024 at 09:56:58 AM PDT
Subject: Creek encampment and trash Woodland Ave area
Good morning,
Thank you for contacting us again. We do not have enforcement powers, but coordinate with our member entities.

It is very frustrating because when one area is cleared, the encampment moves to another area of the creek.

I do know that this encampment has been brought to the attention of the City Manager. I will inquire about an action plan- the individual did not want to move to a shelter, so there may be a basis for removal in addition to the water quality concerns. Certainly the creek is a dangerous place to be during winter storms.

We will be in the creek in this area next week and will inspect from the creek bed.

Thanks,
Tess Byler, PG, CHG
San Francisquito Creek Joint Powers Authority
Original message:
************************************************************************* Hi - It's not just a trash, illegal dumping, but dwelling on the creek, with "development" of the bank dirt, campfire, equipment, etc. visible from backside of properties Edgewood (3 houses) - on the EPA side of the bank. Along Woodland Ave.

Details of whom we've been working with recorded on:

Given the issue is right at the cusp of the two cities and two counties, we're not sure who else can help.

There's a lot of debris and bank digging / deforming happening, not to mention human waste into the creek.

Hope you give this some attention to get the issue addressed.

Thank you.
*Please note my new work cell phone: 650-304-4998*
Tess Byler, Certified Hydrogeologist CA #928
Stormwater QSD CA #25311
Senior Project Manager
San Francisquito Creek Joint Powers Authority
750 Menlo Avenue, Suite 250

2 Menlo Park, CA 94025
Direct line: 650/643-1454

This email has been scanned for spam and viruses. Click here to report this email as spam.

5 On Jun 10, 2024, at 8:39 AM, wrote:

Hello Gerald
,

The progress this person is ma
king on the encampment unimpeded is alarming and very
concerning. From our discourse, we understood you were taking action to remove the encampment, and clean up the creekbed. Please let us know when we can expect this to happen.

Thank you,

On Jun 9, 2024, at 1:46 PM, > wrote:

Hi Gerald,
There is definitely som
eone living there now.

They're dug stairs down the side of the creek.

One picture shows jeans and other clothes strewn about the creek.

The other picture shows large water storage tank and bins and bags filled with clothes (and if you zoom in to the left of the white water tank you can see someone partially obscured by the trees.

I am growing more concerned about this site.

What timeframe can we expect action?

6 On Thu, May 30, 2024 at 4:35 PM
> wrote:

Hi Gerald,
It appears the pallet work in the creek is continuing. Now it is in the creek and appears to be trying to obstruct the creek flow. See the attached photo. This is getting more concerning. Please update us with your plans for addressing this problem.

7 On Tue, May 28, 2024 at 8:32 AM,
> wrote:

Good morning Gerald,
I'm writing this morning with an update, that because none of the construction materials have been cleaned up since we met, the individual moved the material two doors down and this weekend constructed a dwelling as pictured in the creek at Woodland Ave. , opposite Edgewood. We are very concerned about this development. The neighbors to my right have also sent me photos of more material dumped in the creek behind their house as well. This situation needs to be addressed immediately as there is currently a dramatic escalation of encampment activity going on in this area of the creek.

After our conversation, I was told that the City of East Palo Alto would be sending a crew over to the creek last Friday 5/24/24 to clean up the materials that were being dumped there. No action was taken. Please follow through and get this cleaned up ASAP, and help keep our neighborhoods safe.

Thank you,

Honorable Mayor and Members of the City Council
April 4, 2025

Page 9 ends

Exhibit B
Police Reports

CONTROLLED DOCUMENT

PALO ALTO POLICE DEPARTMENT

DO NOT DUPLICATE

CONTROLLED DOCUMENT

PALO ALTO POLICE DEPARTMENT

DO NOT DUPLICATE

CONTROLLED DOCUMENT

PALO ALTO POLICE DEPARTMENT

DO NOT DUPLICATE

Case number 23-03046
Officer T. Chang

On one summer morning of 2023, one middle age (35~40) white male jumped over the private property on Edgewood Drive back fence from the San Francisquito creek. He walked across that property's backyard towards the property building, spotted by the owners, then hurried over to jump over the side yard fence to Edgewood Drive. The creek was dry. After the property owner met eyes with him, prowler hurried over through the side yard to climb and jump over the front yard fence to access Edgewood Drive. Owner confronted the prowler as he shouted back to exchange some words. He walked towards Newell Road once on Edgewood Drive.

Case Number 23-02704
Officer D. Amani

Summer of 2023.

One prowler jumped over the back fence of the property on Edgewood Drive from the San Francisquito Creek side, at least twice that day per video camera on the property. It is unclear how often he's been jumping over the fence to that or other properties prior to that day. He was seen on another video clip to have also climbed in and walked around the yard in the morning. As he was jumping over the driveway gate from inside our yard to Edgewood Drive that evening, he was spotted by neighbors who were walking their dog. The neighbors notified us and we then called the police about this intrusion. Our camera showed that he had taken our garden shears during the time he was in our yard earlier that same morning. Unclear if other items in the yard were taken.

From: Preeva Tramiel
To: Council, City
Subject: Dark Skies over Palo Alto
Date: Thursday, April 3, 2025 9:24:56 AM
CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.
i
Please strengthen the Dark Sky Ordinance. We deserve good health and a view of the stars! Preeva Tramiel, 767 Addison Ave, Palo Alto, CA 94301
659-208-3580
Sent from my phone, excuse brevity and typos and autocorrect This message needs your attention
This is their first email to your company.

Mark Safe Report
Powered by Mimecast
From: Catherine Whitman
To: Council, City
Subject: KCBS Radio taped telephone interview request
Date: Wednesday, April 2, 2025 8:26:32 AM
CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.
i
Hi,
I am a reporter with KCBS Radio in San Francisco and I'd like to see if a member of the City Council is available for a brief taped telephone interview this morning to talk about the Light Pollution law. Please get back to me as soon as possible as I am on deadline.

Thanks so much!
Cathy Whitman
KCBS Radio News Reporter/Editor/Producer

Audacy | San Francisco
88 Kearny Street
San Francisco, CA 94104
O: +1 415-765-4074
[email protected]
AudacyInc.com

This message needs your attention
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From: Frank Wiley
To: Council, City
Subject: Objection to Dark Sky Regulations...

Date: Tuesday, April 1, 2025 2:53:23 PM
CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.

I'm sure there are a few ardent self-appointed conservationists that see this as a vital issue - but to most residents it's just a dangerous nuisance regulation that would create a good deal of resentment if it was ever enforced.... One would hope that the city council had more important issues to discuss than trying to black-out the city at night.

Frank Wiley
955 Roble Ridge Rd, Palo Alto, Ca 94306

Palo Alto City CouncilApril 7, 2025

Palo Alto City Council
April 7, 2025