Density Significantly Exceeds that Allowed by the Zoning or the Comprehensive Plan.
The Project proposes 65 units (47 studios, 12 one-bedroom and 6 two-bedroom units). Although this is a reduction of five units from the preliminary proposal reviewed by the City Council during the Planned Home Zoning ( “PHZ”) pre -screening, this is still significant ly above the density allowed by the Property’s RM-20 multifamily zoning. The maximum number of units allowed by the zoning would be 10 units. Thus, the Project is proposing six and a half times the maximum allowable zoning density. Furthermore, the Project also far exceeds the allowable residential density identified in the City’s Comprehensive Plan . The Comprehensive Plan would allow a density of 40 units per acre. On this approximately half-acre site, the maximum Comprehensive Plan density would be 20 units. Thus, the Project is proposing 45 units more (or more than three times the density) anticipated by the highest density identified for the Property in the City’s Comprehensive Plan.
With 65 units on approximately one-half acre, the Project density is approximately 126 units per acre for this multifamily residential area . The highest density identified in the Housing Element for any property is 81.25 units per acre for general manufacturing and research, office and limited manufacturing zones. Thus, the proposed Project density is one and one-half times the highest density identified anywhere in the City in the draft Housing Element. This is also far in excess of other planned communities in this area. The Hamilton is located on approximately 1.18 acres and has 36 units for a density of is 33 units per acre . Thus, the proposed Project is well over three times more dense than the neighboring development.
Because by any measure this Project is proposed at an unreasonably high density, The Hamilton encourages the PTC to recommend the Project’s density be significantly reduced.
Inadequate Public Benefit Provided in Exchange for Increased Density.
The Project does not provide a substantial public benefit adequate to justify the significant increase in density. The Project proposes to provide 20 percent affordable housing units (four very-low, four low and five moderate income units) consistent with the City Council direction on the minimum affordability necessary to support a rezoning to PHZ. However, given the significant increase in density, this is a woefully inadequate public benefit. To put it into perspective, a project that proposes 20 percent low-income units would be entitled to a 35 percent density bonus under state density bonus law (Government Code Section 65915). With a maximum Comprehensive Plan density of 20 units, a 35 percent density bonus would result in a 27-unit project.1 In fact, the highest density bonus a project can receive using state density bonus law is 50 percent, which would allow a 30-unit project. Thus, although the PHZ does not require strict adherence to state law, it is important to note that if approved the City would be allowing a far greater density increase than mandated by state law in exchange for far less affordable housing.
1 Strict compliance with the state density bonus law would result in a density bonus of less than 35 percent.
State law generally requires one income category be selected to determine the density bonus; however, many jurisdictions as a policy matter will count units at lower affordability toward the higher category. With four very -low income units, the density bonus percentage would be 20 percent which would be a total project of 24 units. Four low income units would not quality the Project for a density bonus. If the four very- low income were counted toward the low income category, with eight low income units, the Project would quality for a 23 percent density bonus. This would allow a 25-unit project. With five moderate income units, the Project would n ot qualify for a density bonus. If the four very-low and four low income units were counted toward the moderate income category, the Project would qualify for a 15 percent density bonus.
This would allow a 23-unit project.
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Giving away this increased density also does not provide the City significant progress toward meeting its Regional Housing Need Allocation (“RHNA”) for the current Housing Element cycle.
The City needs to plan for 1,556 very-low income units, 896 low income units and 1,013 moderate income units. For more than triple the allowable density, the City obtains only four very-low income units (0.2% of the need), four low income units (0.4% of the need) and five moderate units (0.4% of the need). Understanding that the City needs to plan to develop housing to meet its RHNA goals, the City should not “throw the baby out with the bath water.” Increased housing density should be approved within reasonable limits and certainly not so far in excess of that allowed by the zoning or the Comprehensive Plan, even with state law mandates layered on top. Approving this Project as proposed would unfairly put the burden on the seniors living at The Hamilton to allow the City as a whole to make negligible progress toward its RHNA goals. Therefore, The Hamilton encourages the PTC to recommend the density of this Project be substantially reduced.
Office Use Adds Intensity Without Benefit.
Not only does the Project far exceed the residential density, it also includes office. The Project proposes 9,115 square feet of general office . Office is not a permitted or conditional use in the RM-20 multifamily residential zoning district . Office uses are inconsistent with the City’s Comprehensive Plan for this residential area . Further, general office is a departure from the existing non-conforming medical office . While medical office might serve the “Senior Corner,” general office does not . Instead, general office uses would add intensity and traffic congestion and create additional housing need without benefiting the surrounding community. Thus, The Hamilton urges the PTC to recommend removal of the office use from this Project.
In addition, the City should prepare a housing needs assessment (“HNA”), including consideration of the multiplier effect, as part of the environmental impact report. A HNA would help the City to understand how many employees will occupy the office space and the housing demand that will be generated by those workers . This is especially important in an era where office space per worker is declining, and the number of employees may be higher than anticipated (the average tech worker uses less than 250 square feet of office space).
Finally, the office vacancy rate in Palo Alto is currently at approximately 14 percent indicating there is no need for the development of office in this location where it is neither permitted, nor beneficial.2 Thus, The Hamilton urges the PTC to recommend office be removed from this Project.
Transportation Impacts Potentially Significant.
The environmental impact report and the City in its deliberation regarding the merits of this Project should carefully consider the impact of the additional trips generated by the residential units and office use. The multifamily residential zoning anticip ated 20 units per acre and no office . The Comprehensive Plan anticipated a maximum of 40 units per acre and no office. The intensity of this Project with approximately 126 units per acre and office will far exceed the transportation impacts presented in any environmental review for existing planning documents.
The transportation impact analysis and environmental impact report should not focus only on the impact during peak commute hours, but should consider the impact throughout the day. Such an analysis is important in this “Senior Corner” because many residen ts are home throughout the
2 https://www.nmrk.com/storage-nmrk/uploads/fields/pdf-market-reports/1Q22-SPeninsula-Office- Market_2022-05-31-174425_nzty.pdf
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day. The Hamilton is concerned that the additional traffic generated by the Project will impact their ability not only to drive, but also to walk safely in the neighborhood.
One related issue that should be studied in the transportation impact analysis and environmental impact report is the design of the Project’s entry/exit for the garage onto Middlefield Road. The garage entry/exit is close to the traffic light at University Avenue and may cause significant queuing, which will likely lead to traffic jams on Middlefield Road. This congestion will lead people to try to bypass the traffic by cutting down Byron Street. Byron Street is narrow, and the fully utilized parking on either side makes it impossible for two moving cars to pass each other safely.
Thus, cut through traffic down Byron Street should be analyzed. This is in addition to analyzing the impacts to University Avenue and Middlefield Road that are main arteries in Palo Alto.
Finally, the transportation impact an alysis and environmental impact report should carefully consider the impacts on parking . The Project is proposing 8 2 spaces, which is 28 spaces less than the 110 spaces required. One of the two levels of parking proposes stackers, which can be difficult to operate and maintain. With inadequate and complicated parking, it is reasonable to conclude that many residents, workers and visitors will park off the Property. Consideration of the Project should include parking impacts such as additional miles travelled in search of parking and parking intrusion into surrounding areas.
Air Quality Impacts Should Be Carefully Analyzed.
Closely related to the transportation impacts, are the potential air quality impacts. As noted, this is an area referred to as “Senior Corner.” Seniors are sensitive receptors who are at a heightened risk of negative health outcomes due to exposure to air pollution. The environmental impact report should include a health risk assessment and mitigate the Project to avoid negative health impacts to this sensitive community.
Tree Preservation is of Substantial Importance.
There is a beautiful Coastal Live Oak tree with a trunk diameter of 50 inches growing just over the property line. The canopy stretches approximately 45 feet over the Project site. It provides beauty and shade for the entire block and likely habitat for biological resources such as nesting birds. Careful consideration needs to be given to ensuring that this tree is adequately protected and survives and is in good health after the redevelopment of the Property to minimize the impact of the Project on aesthetics and biological resources. A professional arborist should consider not only the roots, but to how much of the canopy may need to be cut to allow the Project and how this can be limited to avoid impacting the environment.
Other Considerations Impacting Aesthetics, Land Use and Planning.
The setbacks on all streets and sidewalks proposed by the Project are greatly reduced from required setbacks. The required setback along Middlefield is a minimum of 24 feet. The required setback along University Avenue and Byron Street are both 16 feet. The Project would reduce each of these setbacks down to only 10 feet. These setbacks impact the pedestrian experience and may impact safety. These potential impacts should be considered.
The residential portion of the building is 50 feet tall and it is higher for mechanical and elevator equipment. This exceeds the height allowed in the multifamily zoning district. Plans for the Project reveal that a majority of the rooftop will be opened up as a social gathering common area with multiple barbeques, lounges, tables and chairs, including a TV mounted on one of the walls. The Item 6
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aesthetic impacts of the height of the building, any noise impacts from rooftop activities or mechanical equipment should be considered.
Alternatives to Consider.
The Hamilton encourages the environmental impact report to consid er a number of alternatives to the proposed Project. One alternative that could considered is a project that complies with the current zoning and Comprehensive Plan , including density, uses, setbacks, height, etc . This alternative could include additiona l density based on state density bonus law. Even with the additional density allowed by state law, such a project would likely be more responsible to its context and compatible with adjacent development. Another alternative would be a senior project with low income senior housing. Not only is there a need for senior housing and low income senior housing in Palo Alto, such a project may also have reduced impacts (e.g. seniors drive less). The Hamilton urges the PTC to consider either of these alternatives as preferable to the proposed Project.
The Hamilton thanks you for your time and attention to this matter and strongly encourages the PTC not to support moving this Project forward as proposed. The Project should be consistent with or a modest modification to the existing multifamily residential standards, should not include office and should consider providing senior housing.
Sincerely,
Leigh Prince
Leigh F. Prince
Cc: Emily Foley, Planner ([email protected]) Jonathan Lait, Planning Director ([email protected]) Molly Stump, City Attorney ([email protected]) Christopher Ream, President, The Hamilton HOA ([email protected])
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From: Aram James
To: Binder, Andrew; Tony Dixon; KEVIN JENSEN; Jeff Rosen; Sean Allen; Filseth, Eric (Internal); [email protected]; Foley, Michael; Afanasiev, Alex; Lee, Craig; Council, City; Planning Commission; GRP-City Council; Bains, Paul; Winter Dellenbach; Shikada, Ed; Gennady Sheyner; Jay Boyarsky; Joe Simitian; Supervisor Otto Lee; Supervisor Susan Ellenberg Subject: minor-traffic-stops-plummet-in-months-after-lapd-policy-change? Date: Monday, November 14, 2022 11:31:11 AM
CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.
But why is PAPD Chief Andrew Binder unwilling to stop racially loaded pretext stops? and adopt a program similar to the LAPD ? See Binder’s answer on pretext stops- to Weekly reporter Gennady Sheyner in his Battling Bias in Policing piece dated Nov 4, 2022 ( see below the latines piece below) https://www.latimes.com/california/story/2022-11-14/minor-traffic-stops- plummet-in-months-after-lapd-policy-change?_amp=true
https://www.paloaltoonline.com/news/2022/11/04/battling-bias-in-law- enforcement-what-data-reveals-about-the-palo-alto-police?utm_source=express- 2022-11-04&utm_medium=email&utm_campaign=express
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If you need assistance reviewing the above documents, please contact the Project Planner or call the Planner-on- Duty at 650-617-3117 or email [email protected] Attachment D
Project Plans
In order to reduce paper consumption, a limited number of hard copy project plans are provided to Board members for their review. The same plans are available to the public, at all hours of the day, via the following online resources.
Directions to review project plans, TDM plan, and environmental documents, including the Draft and Final EIR online:
1. Go to: bit.ly/PApendingprojects
2. Scroll down to find “660 University” and click the address link
3. On this project-specific webpage you will find a link to the project plans and other important information
Direct Link to Project Webpage:
https://www.cityofpaloalto.org/News-Articles/Planning-and-Development-Services/660- University-Avenue
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City Council
Staff Report
From: City Manager
Report Type: ACTION ITEMS
Lead Department: Transportation
Meeting Date: November 10, 2025
Report #:2509-5227
TITLE
Approval of the Four-Quadrant Gate System as the preferred Quiet Zone Implementation Measure at the Churchill, Meadow, and Charleston Rail Crossings as Recommended by the Rail Committee; CEQA status - categorically exempt.
RECOMMENDATION
The Rail Committee and staff recommend approving the Four-Quadrant Gate System as the Quiet Zone implementation Measure at the Churchill Avenue, Meadow Drive, and Charleston Road Rail Crossings for Quiet Zones along the Caltrain Corridor in Palo Alto.
EXECUTIVE SUMMARY
Implementation of Quiet Zones was identified as a Council Priority for Palo Alto in March 2024.
To this end, City staff completed a Quiet Zone Study to evaluate rail crossings at Churchill Avenue, E. Meadow Drive, and Charleston Road in accordance with Federal Railroad Administration (FRA) regulations. Rail Committee then considered initial findings on August 20, 2024 and directed staff to explore two options:
Implementing a four-quadrant gate system in order be eligible for a Quiet Zone; and Installation of a wayside horns system.
In accordance with state law, diagnostic and follow up meetings were held on these options with representatives from the FRA, California Public Utilities Commission (CPUC), and Caltrain. A public engagement meeting was also held to gather feedback from community members.
Community members expressed strong support for implementing Quiet Zones through the installation of Four-Quadrant Gate Systems. The current estimated cost for implementing wayside horns at the three locations is approximately $1.5 million, while the four-quadrant gate system at the three locations is approximately $4.1-5.6 million. The project will likely require funding through a combination of the City’s Capital Improvement Program funds and Measure K Business Tax revenue for either of the proposed alternatives.
On September 16, 2025, Rail Committee unanimously recommended the Four Quadrant Gate System for implementation of a Quiet Zone along the Caltrain corridor at the existing at-grade Item 7
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rail crossings in Palo Alto at Churchill Avenue, E. Meadow Drive, and Charleston Road, and that this be agendized as an action item for the full City Council. This measure is intended as an interim improvement until permanent grade separations are constructed. Accordingly, staff is seeking approval to proceed with the installation of Four-Quadrant Gate Systems as the safety enhancement required to implement Quiet Zones at these crossings.
BACKGROUND & ANALYSIS
Palo Alto has four at-grade crossing locations with 104 daily Caltrain services in addition to unscheduled Union Pacific freight services. At each of these locations, Federal regulations require that locomotive horns produce sounds from 96 to 110 decibels for at-grade crossings and that trains begin sounding these horns 15–20 seconds before entering public rail grade crossings, and no more than one-quarter mile in advance. These train horns create noise impacts in neighborhoods surrounding railroad crossings in Palo Alto. The extent and severity of noise impacts is affected by a range of factors including horn noise level and character, ambient noise levels, and prevailing winds.
In September 2024, the Peninsula Joint Powers Board (JPB) completed a multi-decade project to electrify Caltrain operations. Following electrification, Caltrain and Cities along the Peninsula noted an increase in noise complaints related to Caltrain horns, which had initially been set toward the high end of the legal limit. In November 2024, Caltrain adjusted horn noise levels to the low end of the legal range.
The City of Palo Alto (City) has received several requests for consideration of a Quiet Zone (QZ) at crossings along the Caltrain Corridor. As part of the Palo Alto Council Priority process, implementation of quiet zones has been identified as a Council Priority consistent with the goals of Public Safety, Wellness and Belonging. For this reason, on March 4, 2024, City Council approved an agreement with Kimley Horn and Associates for performing a Quiet Zone Study (Staff Report 2311-2269)1.
As the first phase of the quiet zone project, the City of Palo Alto in collaboration with the City of Menlo Park conducted a QZ study for establishing a quiet zone at the Palo Alto Avenue/Alma Street crossing. The design of the improvements required for implementation of QZ at Palo Alto Avenue was completed in early 2025 and associated improvements are currently under construction. After the project is constructed, the City will be eligible to apply to the FRA for establishment of a quiet zone in which train horns do not need to be sounded under normal circumstances. Gate bells would still sound and emergency train horns use would be under the discretion of the train engineer.
The City is now undertaking the second phase of the quiet zone project for the remaining three 1 City Council Meeting, March 4, 2024; Consent Item SR# 2311-2269 https://portal.laserfiche.com/Portal/DocView.aspx?id=70841&repo=r- 704298fc
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at-grade crossings of Churchill Avenue, E. Meadow Drive, and Charleston Road. Quiet zone improvements at these locations will serve as an interim measure to mitigate noise impacts before planned Grade Separations are constructed at these crossings.
The Federal Railroad Administration (FRA) Title 49 regulations establish safety requirements for local agencies that wish to mitigate train horn noise impacts by establishing Quiet Zones. The regulations require agencies to complete a quiet zone study to evaluate the Quiet Zone Risk Index (QZRI) and assess Supplemental Safety Measures (SSM) needed to make a crossing eligible for a quiet zone. In total, FRA lists fourteen recognized SSMs. Based on street geometry and nearby signal operations, the only feasible SSM identified for the three crossing locations under consideration in Palo Alto was a four-quadrant gate system.
After completing the initial review of the existing conditions and analysis of the crossings. Staff presented various options for consideration of QZ to the Rail Committee on August 20, 2024 (Staff Report 2405-3805).3 At this meeting, Rail Committee selected two alternatives to advance to concept development:
Option 1: Implementing a Four-Quadrant Gate System at Each Crossing to bring the QZRI below the existing Risk Index With Horns (RIWH) and qualify the crossings as quiet zones. This also satisfies the QZ implementation methodology of providing an approved SSM at each crossing within the quiet zone.
Option 2: Implementing Wayside Horns, which would not qualify the crossings as quiet zones, but would reduce and localize noise impacts. Wayside horns are allowed to be installed at crossings that are already equipped with flashing lights and automatic gates.
The horns must sound in the same sequence and at the same decibel level as train horns, and may be placed on the warning device, or installed on a separate post, and oriented to face the roadway and oncoming traffic.
Based on feedback from the Rail Committee, initial concepts for the two options above were prepared and discussed with CPUC, FRA and Caltrain staff at a pre-diagnostic and field diagnostic meeting held on October 22, 2024. The initial conceptual plans were then revised to incorporate feedback from diagnostic meetings.
City staff also conducted a public outreach meeting to seek feedback and comments on April 16, 2025. A total of 17 attendees participated in the community meeting. In addition, staff received several emails and phone calls. Residents generally supported Quiet Zones efforts, particularly full establishment of a Quiet Zone using the four-quadrant gate system. One resident, however, opposed the quiet zone concept citing potential safety concerns resulting from the “no horns” condition. Many residents viewed wayside horns as an insufficient measure for addressing project goals.
3 Rail Committee, August 20, 2024; Action item SR# 2405-3805 https://portal.laserfiche.com/Portal/DocView.aspx?id=87322&repo=r-704298fc Item 7
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In addition to community input, the project consultant team undertook case study reviews from across the country, which suggest potentially lower operational and maintenance concerns associated with quadrant gates relative to wayside horns. This difference may be due to the higher prevalence of quadrant gates and correspondingly lower number of suppliers and technical support available for wayside horns. In some cases where wayside horns have been installed, local agencies have subsequently chosen to remove the horns due to ongoing maintenance issues and the time it takes to repair a faulty wayside horn system. In addition, some local agencies noted that railroad engineers continued to use locomotive horns even after wayside horns were in operation.
Both the FRA and CPUC noted that the Caltrain corridor sees a significant level of train collisions, given its high speed, high volume and proximity to urban and suburban areas. Wayside horns do not provide an added barrier to entry of the track area, where four-quadrant gates would provide additional gates on the “departure” side of the railroad track. Relative to wayside horns, the four-quadrant gate system would enhance the barrier to entry to the tracks and reduce the potential for gate go-arounds, thereby reducing the ability of users to enter the trackway while a train is operating in the area.
On the other hand, wayside horns cost less and retain the warning mechanism for approaching trains. Both strategies deviate from Caltrain’s standard practice limiting locomotive horn use.
These measures are implemented by local agencies to reduce noise, and because they are initiated by the City, certain responsibilities—including maintenance, operations and other risks—may shift to local agencies.
While the City is proceeding with grade separation projects, in the absence of grade separation, the Four Quadrant Gate System has been identified as the required mitigation measure needed to support the future high speed rail. It would therefore need to be implemented in order for High Speed Rail to operate in the area.
In terms of total cost, implementation of wayside horns is typically less expensive than the Four- Quadrant Gate System. The current estimated cost for implementing wayside horns at the three locations is approximately $1.5 million, while the four-quadrant gate system at the three locations is approximately $4.1-5.6 million. The project will likely seek funding through a combination of the City’s Capital Improvement Program funds and Measure K Business Tax revenue for either of the proposed alternatives. As noted above, four-quadrant gate systems are identified as required environmental mitigation measures for the California High-Speed Rail project, which may present an opportunity for the City to pursue funding through that program.
However, the California High-Speed Rail project is currently facing funding challenges, and therefore, the likelihood of securing funding from that source is considered very limited.
Regarding installation time, staff will need to complete similar steps for both alternatives, including developing agreements, conducting reviews, and obtaining approvals from the CPUC, Caltrain, and FRA. Given the potential for limited involvement from these external agencies and the relatively lower design complexity of the wayside horn system, its installation is anticipated Item 7
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to require approximately 36 to 42 months. This represents a shorter timeframe compared to the estimated 42 to 60 months for installation of the Four Quadrant Gate System.
After considering a range of factors—including safety factors, construction costs, ongoing maintenance needs and technical support, regulatory compliance, community feedback and risk the Rail Committee on September 16, 2025 (Staff Report # 2507-4951) 5 unanimously selected the Four Quadrant Gate System for implementation of Quiet Zone along Caltrain corridor at the existing at-grade rail crossings in Palo Alto at Churchill Avenue, E. Meadow Drive, and Charleston Road as interim improvements until grade separations are constructed. In light of the potential shorter timeframe for wayside horn implementation and significance of this decision, the Committee also recommended the full City Council discuss this as an action item. Accordingly, subject to City Council concurrence, staff is seeking approval to proceed with the installation of Four-Quadrant Gate Systems as the safety enhancement required to implement Quiet Zones at these crossings.
More recent discussion with Caltrain indicated a higher cost to implement Four Quadrant Gate Systems at these three crossings and has estimated the cost to be in the range of $5.0 to 5.6 million for Four Quadrant Gates Systems that include Caltrain project management and oversight. Additionally, it was noted that if Caltrain proceeds with both the design and construction phases, utilizing on-call consultants and contractors could lead to greater efficiencies with respect to the implementation of improvements—potentially reducing the implementation timeline for the four-quadrant gate systems to 36 months.
FISCAL/RESOURCE IMPACT
The Quiet Zone Study is currently funded in the Transportation and Parking Improvements capital project (PL-12000). Funding for the study of $178,559 was included in the FY 2026 Adopted Capital Budget for PL-12000. Depending upon the City Council direction additional funding for the implementation will be subject to Council appropriation in future years as part of the annual budget process. Based on the Council direction for the recommended Quite Zone implementation, staff will return to Council to request appropriation of Measure K Business Tax revenue that was set aside by the Council for Transportation Safety projects for design and construction of improvements.
STAKEHOLDER ENGAGEMENT
Stakeholder engagement on this issue has included a community meeting on April 16, 2024, Rail Committee meetings on August 20, 2024 and September 16, 2025, and a diagnostic meeting with various stakeholders representing FRA, CPUC, and Caltrain on October 22, 2024.
Outreach for the community meeting included mailers to all residents within 1000’ radius of the 5 Rail Committee, August 20, 2024; Action item SR# 2507-4951 https://portal.laserfiche.com/Portal/DocView.aspx?id=222522&repo=r-704298fc Item 7
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crossings vicinity. Outreach for the Rail Committee meetings included noticing in the City’s Transportation newsletter and email blasts through the City Clerk’s meeting notification system.
Notices for all of these public meetings also included publishing on City calendar.
ENVIRONMENTAL REVIEW
This proposed project involves the installation of quadrant gate systems and is categorically exempt under CEQA. Section 15301(f) of the CEQA Guidelines provides a categorical exemption for the addition of safety or health protection devices used during construction or in conjunction with existing structures and facilities. In addition, CPUC Rule of Practice and Procedure
17.1(h)(A)(5) provides a CEQA exemption for alterations in railroad crossing protection, and Rule
17.1(h)(A)(6) provides a CEQA exemption for crossing alterations described in Guideline 15301(c) and (f). Based on these exemptions installation of the four quadrant gate systems does not require additional CEQA review.
ATTACHMENTS
Attachment A: Palo Alto Quiet Zone Report
APPROVED BY:
Ria Hutabarat Lo, Chief Transportation Official
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Quiet Zone Implementation Study
Prepared for:
City of Palo Alto
250 Hamilton Avenue
Palo Alto, CA 94301
Prepared by:
Kimley-Horn and Associates, Inc.
10 S. Almaden Boulevard
Suite 1250
San Jose, CA 95113
Prepared on:
June 26, 2025
This document, together with the concepts and designs presented herein, as an instrument of service, is intended only for the specific purpose and client for which it was prepared. Reuse of and improper reliance on this document without written authorization and adaptation by Kimley-Horn and Associates, Inc., shall be without liability to Kimley-Horn and Associates., Inc.
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Kimley-Horn.com 10 Almaden Boulevard, Suite 1250, San Jose, CA 95113 669-800-4130
CITY OF PALO ALTO QUIET ZONE STUDY
TABLE OF CONTENTS
Background ............................................................................................................................................. 3 Scope of Work ......................................................................................................................................... 3 Document Review and Initial Data Collection........................................................................................ 3 Quiet Zone Analysis ................................................................................................................................ 5 SSM at Each Crossing ......................................................................................................................... 6 SSM at Some Crossings (QZRI Less Than RIWH) ............................................................................... 6 No SSM (QZRI Less Than NSRT) ........................................................................................................ 6 Quiet Zone Alternative – Wayside Horns (WSH) ...................................................................................... 7 Wayside Horns Case Study – Flagstaff, AZ .......................................................................................... 7 Prevalence of Wayside Horns .............................................................................................................. 8 Quiet Zone Evaluation ............................................................................................................................. 8 Conceptual Design .................................................................................................................................. 9 Field Diagnostic Meetings ...................................................................................................................... 10 Cost Estimates ...................................................................................................................................... 10 Outreach and Coordination .................................................................................................................... 10 Recommendations ................................................................................................................................. 11 Next Steps............................................................................................................................................. 11 Final Design ....................................................................................................................................... 11 Permitting .......................................................................................................................................... 12 Funding ............................................................................................................................................. 12 Construction....................................................................................................................................... 12 Quiet Zone Certification...................................................................................................................... 12 Continued Outreach ........................................................................................................................... 13 List of Appendices
Appendix A Full Quiet Zone Analysis
Appendix B Conceptual Designs
Appendix C Field Diagnostic Meeting Minutes
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Kimley-Horn.com 10 Almaden Boulevard, Suite 1250, San Jose, CA 95113 669-800-4130
BACKGROUND
There are four at-grade vehicular railroad crossings within the City of Palo Alto, all along the Caltrain corridor, whose right of way is owned by the Peninsula Corridor Joint Powers Board (PCJPB). Per Federal Railroad Administration (FRA) requirements, locomotive engineers are required to sound their horns upon approach to at-grade crossings in a four-blast sequence, beginning either 20 seconds or ¼- mile upstream of the at-grade crossing. In Palo Alto, these four vehicular at-grade crossings span over
3.5 miles – meaning that for each train passing through this city, the train horns sound sixteen times (excluding any train horns sounded on approach to the Caltrain stations within the City). With Caltrain being a transit agency boasting robust service, trains pass through Palo Alto quite frequently; Union Pacific Railroad (UPRR) also maintains trackage rights, allowing them to use this corridor for freight operations. These train movements, and the required horn soundings, result in significant noise pollution and quality of life degradation for nearby residents and businesses.
For the reasons listed above, the City Palo Alto (subsequently referred to as “City”) has undertaken a study to determine the feasibility of implementing a quiet zone along this railroad corridor.
SCOPE OF WORK
The work accomplished under this study included analysis, conceptual designs, field diagnostic meetings, and public outreach for the four at-grade crossings. The crossings located in the City of Palo Alto are shown in Table 1 below.
Table 1: Crossings located in the City of Palo Alto
Crossing DOT# Crossing Roadway Name
754992N Palo Alto Avenue
754998E Churchill Avenue
755010S East Meadow Drive
755011Y Charleston Road
Source: FRA Office of Safety Analysis (https://safetydata.fra.dot.gov/officeofsafety/publicsite/crossing/crossing.aspx) The northernmost at-grade crossing in Palo Alto (Palo Alto Avenue) was evaluated in a previous quiet zone implementation study, which was then followed by a final design phase. The Palo Alto Avenue crossing is approaching the construction phase for its set of quiet zone improvements, which is comprised of a raised median on both sides of the tracks. Any improvements to the remaining crossings in the City would then append the quiet zone at Palo Alto Avenue. The purpose of this study is to determine the recommended set of improvements at the remaining three crossings in the City – Churchill Avenue, East Meadow Drive, and Charleston Road.
Kimley-Horn performed the necessary analysis prescribed by the FRA, prepared draft conceptual designs of the improvements to each of the three remaining at-grade crossings within the scope, scheduled and attended diagnostic field meetings with stakeholders, and assisted the City in public outreach efforts.
DOCUMENT REVIEW AND INITIAL DATA COLLECTION
Kimley-Horn staff performed an initial site visit to evaluate the existing conditions of the grade crossings and assessed both the opportunities and constraints for the potential improvements. This investigation Item 7
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Kimley-Horn staff also reviewed available documents from the FRA, including existing U.S. DOT Inventory Forms and historical incident reports. The inventory reports detail the existing conditions of the crossing, and include vital information about the roadway infrastructure, railroad infrastructure, crossing geometry, railroad organization information, train information (including daily counts and timetable speeds), and general location information. The incident reports include collision details and provide insight into historic events at each crossing, including what, if any, safety measures were implemented at that time. The incident reports allowed Kimley-Horn staff to directly compare the data for each crossing and identify major safety differences among the crossings.
Since 2015, there have been 26 incidents along this three-crossing section of the corridor. Table 2 shows a breakdown of the incidents, including the year of the incident and a summary of the incident.
Table 2: Incidents at Each Crossing from 2015 to present Crossing
DOT#
Crossing
Roadway
Name
Date of
Incident Type of Incident
Injury/Fatality
754998E Churchill
Avenue
4/16/2023 Person Fatality
9/09/2022 Vehicle (unoccupied) None reported
5/10/2021 Vehicle (occupied) None reported
1/21/2021 Person Fatality (intentional)
11/15/2019 Vehicle (unoccupied) None reported
8/03/2018 Vehicle (occupied) None reported
10/16/2017 Vehicle (unoccupied) None Reported
6/15/2017 Vehicle (unoccupied) None Reported
5/22/2017 Vehicle (occupied) None reported
755010S
East
Meadow
Drive
2/20/2024 Person Fatality
1/26/2024 Person Fatality
7/06/2023 Person Fatality
7/23/2022 Person Fatality (intentional)
1/19/2017 Vehicle (occupied) None reported
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9/19/2016 Vehicle (occupied) Injury
9/13/2015 Vehicle (occupied) None reported
755011Y Charleston
Road
1/23/2024 Vehicle (unoccupied) None reported
12/02/2021 Vehicle (unoccupied) None reported
10/26/2021 Person Fatality (intentional)
8/16/2019 Vehicle (unoccupied) None reported
3/25/2018 Vehicle (unoccupied) None reported
2/12/2018 Vehicle (unoccupied) None reported
10/05/2017 Vehicle (unoccupied) None reported
12/23/2016 Vehicle (occupied) Fatality (intentional)
1/25/2015 Person Fatality (intentional)
Source: FRA Office of Safety Analysis (https://safetydata.fra.dot.gov/officeofsafety/publicsite/crossing/crossing.aspx) The City collected traffic volumes in April 2023 at each crossing to determine the mode share for vehicles, bicycles, and pedestrians. See Table 3 for a summary of the traffic counts collected. In 2025, Caltrain operates 104 Caltrain commuter trains per day across these crossings. Of note, Caltrain may adjust service frequency in the future to meet customer demand. Based on Caltrain’s 10-Year Strategic Financial Plan as of December 2024, the assumed weekday trains per day (TPD) will increase to 116 TPD in 2029 and to 128 TPD in 2031.
Table 3: Summary of daily total traffic volumes at study locations Crossing
DOT#
Crossing Roadway
Name
Pedestrian Count Bicycle Count Vehicle Count
WB EB WB EB WB EB
754998E Churchill Avenue 105 9 298 187 1,162 4,622
755010S East Meadow
Drive 58 5 224 370 3,028 3,716
755011Y Charleston Road 77 1 186 224 4,416 5,768
Source: Traffic Counts provided by the City of Palo Alto
QUIET ZONE ANALYSIS
There are multiple ways a section of railroad corridor can achieve quiet zone status, which are outlined below. These include the installation of Supplemental Safety Measures (SSM) at all crossings, a partial implementation of SSMs across the crossings, and in rare cases, demonstrating that the existing risk index qualifies for a quiet zone.
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SSM AT EACH CROSSING
The first method is to provide a Supplemental Safety Measure (SSM) at each crossing within the quiet zone. SSMs are defined by the FRA in 49 Code of Federal Regulations Appendix A to Part 222. It includes options such as “four-quadrant” (or “exit”) gates, non-traversable medians, one-way streets with entry gates, and temporary or full crossing closure. Table 4, below, shows the full list of 14 SSMs accepted by the FRA.
Table 4: SSM Codes and Definitions
SSM
Code
SSM Definition
1 Temporary Closure of a Public Highway-Rail Grade Crossing 2 Permanent Closure of a Public Highway-Rail Grade Crossing 3 Grade Separation of a Public Highway-Rail Grade Crossing 4 Four-Quadrant Gates Upgrade from Two Quadrant gates, No Vehicle Presence Detection 5 Four-Quadrant Gates Upgrade from Two Quadrant Gates, with medians and no Vehicle Presence Detection
6 Four-Quadrant Gates Upgrade from Two Quadrant gates, with Vehicle Presence Detection 7 Four-Quadrant Gates Upgrade from Two Quadrant gates, with medians and Vehicle Presence Detection
8 Four-Quadrant Gates New Installation, No Vehicle Presence Detection 9 Four-Quadrant Gates New Installation with medians and no Vehicle Presence Detection 10 Four-Quadrant Gates New Installation with Vehicle Presence Detection 11 Four-Quadrant Gates New Installation with medians and Vehicle Presence Detection 12 Mountable medians with Reflective Traffic Channelization Devices 13 Non-Traversable Curb Medians with or without Channelization Devices 14 One-Way Streets with Gates
Source: FRA Quiet Zone Calculator (https://safetydata.fra.dot.gov/quiet/ssm.aspx)
SSM AT SOME CROSSINGS (QZRI LESS THAN RIWH)
The second method to qualify for a quiet zone is a partial establishment of SSMs at one or more crossings within the proposed quiet zone such that the Quiet Zone Risk Index (QZRI) is reduced to a level at or below the Risk Index With Horns (RIWH). The RIWH is the risk associated with all crossings included in the specified quiet zone when train horns are sounded per FRA requirements. Under this method of quiet zone qualification, SSMs may not be required at all crossings. The quiet zone rule defines a rate of effectiveness for each SSM to formulaically assign risk reductions to each crossing.
NO SSM (QZRI LESS THAN NSRT)
The third and final method by which a quiet zone can be achieved is if the Quiet Zone Risk Index (QZRI) along the section of corridor is at or below the Nationwide Significant Risk Threshold (NSRT). The NSRT is defined as the average of the risk indexes for all grade crossings in the country where train horns sound. As of May 2025, the NSRT is currently equal to 15,488.00. Because the NSRT is representative of all grade crossings in the country, it includes grade crossings which may have undergone safety improvements and may have implemented the full range of crossing improvements or implemented significantly impactful SSMs or ASMs, like one-way streets or partial closure. If the QZRI with no Item 7
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However, this corridor does not qualify for a quiet zone in its current state, unless crossing closures are considered. Crossing closures were not determined to be in the best interest of the community.
Therefore, the NSRT method was not considered for the study.
QUIET ZONE ALTERNATIVE – WAYSIDE HORNS (WSH)
An alternative to a quiet zone, but one that still promotes noise reduction, would be the installation of wayside horns. Wayside horns are fixed audible warning devices, which are physically present at the crossing. The wayside horn is required to sound at the same frequency, decibel level, and duration as a traditional train horn. The noise reduction stemming from a wayside horn is due to the fixed nature of the horn. Where the noise distribution of a traditional train horn moves as the train moves, the wayside horn stays fixed at the crossing, with the horn itself directed at the stop line for oncoming motorists. The result is a reduction in noise for those that are not directly adjacent to the crossing. It should be noted that for those directly adjacent to or at the crossing, the result is that the full volume of all four sounds of the horn can be heard.
While a wayside horn is not a quiet zone measure, it is evaluated as a one-for-one replacement of the train horn. The requirements for installation of a wayside horn are noted in Appendix E to Part 222 of the Code of Federal Regulations – Requirements for Wayside Horns. As noted in Appendix E to Part 222, wayside horns must provide a minimum sound level of 92 dB(A) – maximum 110 dB(A) – when measured 100’ from the centerline of the nearest track. The horn system is required to sound a minimum of 15 seconds prior to the train’s arrival at the crossing.
WAYSIDE HORNS CASE STUDY – FLAGSTAFF, AZ
Kimley-Horn reached out to internal partners nationwide to gather information surrounding wayside horns.
The most recent example evaluated was a 2010 WSH installation in Flagstaff, Arizona. In this location, Fanning Drive (Crossing DOT# 025129Y) and Steves Boulevard (Crossing DOT# 025099J), have implemented wayside horns. These crossings see about 100 to 120 trains per day (TPD) operating at a maximum authorized speed of 55mph. The TPD is similar to Caltrain’s current 104 TPD.
These two crossings are part of a larger quiet zone project with three other crossings. The other crossings do not use wayside horns. Instead, they have implemented other SSMs such as median upgrades or conversion to a one-way street. Of note, the city has fielded continuous complaints from residents since their installation in 2010. There has also been community feedback noting equity issues that arise from certain parts of the city receiving what the community refers to as a “true” quiet compared to a wayside horn implementation with the same frequency of train horns sounding in a localized area.
The City of Flagstaff installed wayside horns manufactured by Railroads Controls Limited (RCL), which was acquired by Wabtec Corporation in 2015. The sound level of the wayside horns is recertified every two years using a sound meter purchased by the City – this recertification involves ensuring the wayside horns sound at the required decibel levels as prescribed in Appendix E to Part 222 of the Code of Federal Item 7
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Due to the factors of community feedback, lack of ongoing technical support, and cumbersome recertification, the City of Flagstaff is seeking funding to replace the wayside horns with a four quadrant gate system at both the Fanning Drive and Steves Boulevard crossings.
PREVALENCE OF WAYSIDE HORNS
Wayside horns are not considered quiet zone crossings on their own, but may be listed as quiet zone crossings if they are included as part of a larger quiet zone. Because the City of Palo Alto is working toward a quiet zone on Palo Alto Avenue / Alma Street, the crossings at Churchill Ave, E Meadow Dr, and Charleston Rd could be appended to this existing quiet zone.
Kimley-Horn also evaluated the usage of wayside horns on a nationwide basis. Kimley-Horn used data published by the FRA on April 30, 2025, and found that there are 5,757 crossings listed as having either a partial or full/24-hour quiet zone. Of these 5,757 quiet zone crossings in the FRA Crossing Inventory Dataset, 76 crossings, or 1.3% of crossings, have wayside horns. There are a total of 672 crossings with wayside horns, though as noted, only 76, or 10%, of wayside horn crossings are part of larger quiet zones. implement SSMs or wayside horns.
Figure 1: Diagram comparing total quiet zone crossings and quiet zone crossings with wayside horns Source: FRA Office of Safety Analysis (https://safetydata.fra.dot.gov/officeofsafety/publicsite/crossing/crossing.aspx)
QUIET ZONE EVALUATION
Kimley-Horn used the FRA Quiet Zone calculator, an online tool provided by the FRA, to determine what upgrades would generate quiet zone approval. Based on the existing conditions at each crossing, Kimley- Horn staff determined the Supplemental Safety Measure treatment most applicable for these three locations to be four-quadrant gates with vehicle presence detection.
Wayside Horns Crossings,
76, 1%
Quiet Zone Crossings,
5757, 99%
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Kimley-Horn.com 10 Almaden Boulevard, Suite 1250, San Jose, CA 95113 669-800-4130 As noted in Table 4, there are 14 total SSMs accepted by the FRA. Full closure of the crossings was not evaluated as the implications for equity and access would likely exceed the cost for implementation of SSMs and temporary closure during peak periods would likewise be impractical. Conversion of roadways from two-way to one-way traffic is another SSM that was not considered as part of this study due to the impracticality of converting residential roadways into one-way streets; similar concerns for equity and access arise when evaluating one-way traffic. All three crossings are less than 60’ from an adjacent roadway (Alma Street); because of this proximity, installation of mountable or non-traversable medians would not qualify as an SSM. Four quadrant gates become the only available option; since all three crossings are currently equipped with gates, it would be an upgrade from the existing two-quadrant system.
A four-quadrant gate system prohibits vehicles from driving around gates in the down position and moving onto the tracks during a train event. The gates on the departure side of the crossing have a delayed lowering compared to the entry gates to ensure no vehicles are on the tracks and at risk of fouling the tracks. It should be noted that vehicle presence detection is required at all crossings implementing a four- quadrant gate system in California per California Public Utilities Commission (CPUC) General Order No. 75-D. Because of this, if a vehicle is detected in the trackway during gate activation, the exit gates would also remain in the “up” position and would not descend until the vehicle clears the trackway. See Figure 1 for an example graphic of a four-quadrant gate system as depicted by the California High Speed Rail Authority (CAHSRA).
Source: https://hsr.ca.gov/about/safety/quad-gates/
Wayside horns are not in the Quiet Zone Calculator but are viewed as a direct replacement to SSMs. If wayside horns are applied at each of the three crossings, the quiet zone would qualify through the first listed option for quiet zones – installing SSMs at every crossing.
CONCEPTUAL DESIGN
Kimley-Horn staff prepared conceptual design plans for each of the three at-grade crossings to provide a complete evaluation of the impacts and potential needs for upgrades at each crossing. Kimley-Horn evaluated the four-quadrant gate alternative, as well as wayside horns.
See Appendix B for the finalized conceptual layouts.
Figure 2: Four-quadrant gates
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FIELD DIAGNOSTIC MEETINGS
A preliminary field diagnostic meeting was performed in October of 2024 to evaluate the proposed improvements with relevant stakeholders to determine if the quiet zone is feasible. This field diagnostic included staff from the City, Kimley-Horn, Caltrain, CPUC, and FRA. While UPRR has trackage rights to operate on the corridor, they were not included in the diagnostic meeting.
The draft conceptual designs for SMM installation were provided to all invited to the field diagnostic meeting to allow for review ahead of the meeting. During the field diagnostic meeting, small design revisions were noted by stakeholders, and the conceptual layouts were then updated accordingly.
Kimley-Horn drafted field review minutes following the diagnostic meetings and sent them to stakeholders for review and input. The meeting minutes then incorporated City and stakeholder feedback and were finalized.
See Appendix C for the Field Diagnostic Meeting Minutes.
COST ESTIMATES
Kimley-Horn staff drafted cost estimates for each crossing. These estimates detail approximate infrastructure costs, as well as expected project delivery costs associated with the completion of the project. Construction costs were derived from the following sources:
· Bid results from recent at-grade rail improvement projects in Northern CA. · Caltrans Unit Price Database.
· Project research on wayside horn implementation, adjusted for inflation and geographic location.
Table 5 shows the rough order of magnitude costs determined by crossing for each of the three crossings in the study area.
Table 5: Rough Order of Magnitude Costs for Each Crossing Crossing DOT# Crossing Roadway Name Four-Quad Gate Cost Wayside Horn Cost 754998E Churchill Avenue $1,200,000 $500,000
755010S Meadow Drive $1,670,000 $500,000
755011Y Charleston Road $1,220,000 $500,000
Source: Kimley-Horn prepared the Rough Order of Magnitude cost estimate.
It should be noted that these order of magnitude estimates include a contingency factor, provisions for engineering design and permitting, escalation, and a Caltrain signal design allowance. For the four-quad gate cost, a new signal cabinet at each location has also been included. This is often required by railroads when there are changes to the signaling infrastructure. The wayside horn cost does not include this line item, though it should be noted that the need for a new signal cabinet may be a possibility and could increase the cost at each crossing by approximately $400,000.
OUTREACH AND COORDINATION
The Caltrain corridor is located adjacent to existing residences, schools, and businesses. Due to its proximity to residents and the fact these improvements hinge on safety considerations, this project required public outreach and coordination. The Kimley-horn team developed presentations for use at Item 7
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In these presentations, Kimley-Horn touched on the background of a quiet zone, the process by which a quiet zone can be achieved (including a rough timeline for implementation), what this quiet zone would entail in terms of infrastructure upgrades, and the next steps for the City to implement a quiet zone. A recording of the public meeting for the project will be made available at https://www.paloalto.gov/Departments/Transportation/Transportation-Projects/Quiet-Zone- Studies/Churchill-Avenue-Meadow-Drive-Charleston-Road-Crossings.
RECOMMENDATIONS
Kimley-Horn recommends the City of Palo Alto implement a quiet zone by installing a four-quadrant gate system at each of the three crossings. While the capital costs associated with a four-quadrant gate system are higher than that of wayside horns, the impact to the community will be more significant.
Wayside horns do reduce the noise level for a majority of residents along the corridor, but there will still be train horn blasts sounded for all residents directly adjacent to the crossings themselves, which does not provide the same benefit to the entire surrounding community as would a four-quadrant gate system.
The general community feedback received was in support of a four-quadrant gate system, and viewed wayside horns as a half measure. Additionally, Kimley-Horn’s case study research showed low implementation of wayside horns across the country, with a correspondingly low amount of suppliers and technical support.
Additionally, the FRA and CPUC noted that the Caltrain corridor sees a significant level of train incidents, given its high speed and high volume. Providing the four-quadrant gate system would provide a physical barrier to entry to reduce the potential of gate go-arounds, thereby actively providing a safety enhancement and reducing the ability for crossing users to enter the trackway during a train event.
NEXT STEPS
Following the conclusion of this quiet zone study, the City may begin preparing for the implementation of a quiet zone. For this to occur, the City must still undergo several necessary steps, including developing final engineering plans, acquiring necessary permits, securing funding, undergoing construction, and certifying the quiet zone with necessary agencies.
FINAL DESIGN
After securing board approval to pursue the remaining work for a quiet zone, the City would need to develop Request for Proposals (RFP) for engineering firms to submit a proposal to perform the engineering work associated with the design of the crossing(s).
Typically, the engineering consultant would submit plans, specifications, and estimates (PS&E) to the City and all stakeholder agencies at various levels of design completion, adding additional detail and information through each submittal. Comprehensive demolition, civil improvements, signage and striping, grading and drainage, lighting/traffic signal (if necessary) plans, along with traffic control plans and Item 7
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PERMITTING
Alongside the final design process, the engineering consultant may support the City with the permitting process. CPUC General Order 88-B (GO 88-B) is a permit required for any modifications to an existing rail crossing. Obtaining approval for this permit is paramount to the modification of any grade crossing, as it ensures the plans provided meet CPUC criteria and acts as government approval for safety upgrades.
Caltrain would likely require the City to obtain an encroachment permit for any work performed in the right of way owned by the PCJPB.
In addition to obtaining permits through CPUC, there may need to be an agreement between the City and PCJPB/Caltrain outlining possible cost sharing for design, construction and maintenance.
Environmental clearance would be required through CEQA; the level of environmental documentation required would be a function of the various resources impacted. If federal funding is secured, the crossings would also need to be cleared through NEPA.
FUNDING
The City would also need to secure funding to support the design and construction associated with the quiet zone. Funding sources exist through federal, state, regional, and local levels, and the engineering consultant may be able to support the City with grant applications for some of these funding opportunities.
On the federal level, the FRA offers the Consolidated Rail Infrastructure and Safety Improvements (CRISI) Grant, which is a program funding projects to improve safety, efficiency, and reliability of intercity passenger and freight rail. Municipalities in California have also been successful at obtaining funding through various state grants; the City could, in conjunction with local and state representatives, investigate and lobby for additional funding.
The City may also pursue funding through the Palo Alto Transportation Management Association (PATMA).
CONSTRUCTION
For the improvements to be constructed, the City should hire a firm familiar with performing construction work in and around railroad right-of-way. Depending on PCJPB/Caltrain regulations at the time of construction, construction crews may be required to be trained by Caltrain staff for safety while working near electrified tracks, or Caltrain themselves may install the railroad devices such as automatic gates or wayside horns. The engineering consultant may be tasked with providing construction support to the City, in the form of field visits and general oversight during the construction phase.
QUIET ZONE CERTIFICATION
The City would be required to file the Notice of Intent (NOI) and Notice of Establishment (NOE) for the quiet zone. The NOI can be submitted prior to construction, and requires a minimum 60-day comment period for all parties in the service list. The NOE should be filed after construction, and requires a similar 60-day comment period. After the NOE is approved by the FRA, the quiet zone can be certified and the “No Train Horn” plaques can be visible to motorists.
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CONTINUED OUTREACH
Throughout the final design and construction phases, the engineering consultant should continue to attend public outreach meetings and hearings to support the City. A post-construction meeting will likely be held with the same attendees as the initial diagnostic meeting to secure final approval of the quiet zone.
MAINTENANCE OF CROSSINGS
At-grade crossings require ongoing maintenance to ensure the warning devices and systems are operating appropriately. The level of maintenance required depends on the crossing and its features.
Per CPUC General Order (GO) 72-D, the railroad owner/operator is responsible for the maintenance of the crossing area measuring 2’ outside the rails of each track, and between sets of tracks (if there are multiple tracks less than 15’ apart). Caltrain also maintains train-activated warning devices for each crossing. Additionally, Caltrain is financially responsible for the maintenance of the gates, and does not currently have cost sharing agreements with local agencies.
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APPENDIX A
Full Quiet Zone Analysis
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Palo Alto Quiet Zone
1 2
3 4
5 6
7 8
9 10
11 12
13 14
Mountable medians with Reflective Traffic Channelization Devices Non-Traversable Curb Medians with or without Channelization Devices One-Way Streets with Gates
Four-Quadrant Gates Upgrade from Two Quadrant gates, with Vehicle Presence Detection Four-Quadrant Gates Upgrade from Two Quadrant gates, with medians and Vehicle Presence Detection
Four-Quadrant Gates New Installation, No Vehicle Presence Detection Four-Quadrant Gates New Installation with medians and no Vehicle Presence Detection Four-Quadrant Gates New Installation with Vehicle Presence Detection Four-Quadrant Gates New Installation with medians and Vehicle Presence Detection Four-Quadrant Gates Upgrade from Two Quadrant gates, with medians and no Vehicle Presence Detection
Supplemental Safety Measure (SSM) Codes
Temporary Closure of a Public Highway-Rail Grade Crossing Permanent Closure of a Public Highway-Rail Grade Crossing Grade Separation of a Public Highway-Rail Grade Crossing Four-Quadrant Gates Upgrade from Two Quadrant gates, No Vehicle Presence Detection Item 7
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Palo Alto Quiet Zone
Existing SSM SSM Risk SSM Risk Δrisk
Palo Alto Ave 0 0 102,853.18 13 20,570.64 -82282.54
Churchill 0 0 588,964.84 6 135,461.91 -453502.93
E Meadow 0 0 295,736.94 6 68,019.50 -227717.44
Charleston 0 0 426,060.47 6 97,993.91 -328066.56
Total 353403.86 80511.49
SSM Risk SSM Risk SSM Risk SSM Risk
Palo Alto Ave 13 20570.64 13 20570.64 13 20570.64 13 20570.64 Churchill 0 588964.84 6 135461.91 0 588964.84 0 588964.84 E Meadow 0 295736.94 0 295736.94 6 68019.5 0 295736.94
Charleston 0 426060.47 0 426060.47 0 426060.47 6 97993.91 Total 332833.22 219457.49 275903.86 250816.58
SSM Risk SSM Risk SSM Risk
Palo Alto Ave 13 20570.64 13 20570.64 13 20570.64
Churchill 6 135461.91 6 135461.91 0 588964.84
E Meadow 6 68019.5 0 295736.94 6 68019.5
Charleston 0 426060.47 6 97993.91 6 97993.91
Total 162528.13 137440.85 193887.22
UPGRADE TWO CROSSINGS ONLY
QZ does not qualify
UPGRADE ONE CROSSING ONLY
RISK INDEX WITH HORN: 211872.82
DO NOTHING ALTERNATIVE ADD SSM TO ALL CROSSINGS
QZ qualifies
The following scenarios were analyzed using the FRA Quiet Zone calculator. The Supplemental Safety Measure (SSM) codes are listed below; the full description of SSMs are presented in page 1 of this appendix. To be eligible for a quiet zone, the total risk associated with the zone of interest cannot exceed the risk index with horn (RIWH). For this zone, the RIWH is 211872.82 These calculations are performed under the assumption that the Palo Alto Avenue crossing is to be upgraded in all cases.
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Conceptual Designs
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APPENDIX C
Field Diagnostic Meeting Minutes
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Pre-Diagnostic Meeting
Palo Alto, CA – Multiple Crossings
October 22nd, 2024
Meeting Attendees:
Name Agency/Company Email
Ripon Bhatia City of Palo Alto [email protected] Ade Sogbesan CPUC [email protected]
Eric Walker FRA [email protected]
Lou Tolentino Caltrain [email protected]
Rick Bartholomew Caltrain [email protected]
Janet Wang JPB/Caltrain [email protected]
Amanda Zerbe TASI/Caltrain [email protected]
Fred Sandoval TASI/Caltrain [email protected]
Shawn Lima JPB/Caltrain [email protected]
Blake Silkwood Design/ Kimley-Horn [email protected] Taylor Brown Design/ Kimley-Horn [email protected] Definitions:
• Diagnostic Team: Pursuant to CAMUTCD 8A.01.05a, the diagnostic team needs to include at a minimum, representatives of the highway agency or authority with jurisdiction over the roadway, the railroad with responsibility of the track and signals, and the California Public Utilities Commission with statutory authority over grade crossings. • CPUC Standard No 9: An automatic gate arm used in combination with a Standard No. 8. The gate mechanism may be mounted on the Standard 8 mast or separately on an adjacent pedestal.
The automatic gate shall be designed to fail in the down position. A Crossbuck sign shall be installed on the mast.
• CPUC Standard No. 8: An automatic flashing light signal assembly which, by alternately flashing red lights facing each approach, provides a warning of an approaching train. A Crossbuck sign shall be installed on the mast.
• CPUC Standard No. 8-A: A Standard 8 with additional flashing signals over the roadway on a cantilever arm.
• CPUC Standard No. 9-A: A Standard 9 with additional flashing light signals over the roadway on a cantilever arm.
• CPUC Standard No. 9-E: A Standard 9 installed on the departure side of the at-grade crossing (also known as an exit gate) in addition to the typical approach side of the at-grade crossing (also known as an entrance gate).
• Highway Safety Improvement Act (23 U.S.C. § 407)
• Roadway diet: The narrowing of the roadway and moving vehicle gates to improve visibility of the flashing lights.
• AADT: Annual Average Daily Traffic
• ADT: Average Daily Traffic
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• CAMUTCD: California Manual on Uniform Traffic Control Devices • CPUC: California Public Utilities Commission
• FRA: Federal Railroad Administration
• RRTCD: Railroad Traffic Control Devices.
• RIRO: Right-in Right-Out.
Meeting minutes:
Introductions and Meeting Logistics:
• Draft notes to be provided within two weeks of meeting for Stakeholder review.
Stakeholder comments to be returned within 2 weeks of receipt of notes. • The team reviewed the purpose and definition of a Diagnostic and the Diagnostic Team (CA MUTCD Sections 8A.01, 8A.02 and Code of the Federal Regulations. o “A diagnostic team, consisting of knowledgeable representatives of parties of interest in a highway-rail or highway-LRT grade crossing, using crossing safety management principles, evaluates conditions at a grade crossing to make determinations or recommendations concerning safety needs at the grade crossing. The diagnostic team needs to, at a minimum, include representatives of the highway agency or authority with jurisdiction over the roadway, the railroad or LRT agency with responsibility for the track and signals, and the California Public Utilities Commission (CPUC), which is the state regulatory agency with statutory authority over grade crossings. The removal, reduction, addition, or change in the type of warning devices at each public grade crossing, or publicly- used private grade crossing (as determined by CPUC or a court competent jurisdiction), must be authorized by CPUC. This includes any changes that can affect interconnections with adjacent traffic signals, or any other modification that may impact the safety of the grade crossing. Refer to Public Utilities Code Sections 1201 through 1205, 7537, 99152 and CPUC General Orders 75 and 88, as amended.”
• The FRA shared the District 7 statement.
Crossing Data Review:
Churchill Meadow Charleston
AADT (year) 8,146 (2021) 6,762 (2021) 12,931 (2021)
% trucks 51% 54% 49%
Speed limit (MPH) 25 25 25
Train Counts (year) 108 (2023) 108 (2023) 108 (2023)
Max Train speed (MPH) 79 79 79
Incident History (since
2015)
2023: Pedestrian fatality
2022: Unoccupied
vehicle
2021: Occupied vehicle;
no injuries reported
2024: Pedestrian fatality
2024: Pedestrian fatality
2023: Pedestrian fatality
2022: Pedestrian fatality
2017: Occupied vehicle;
2024: Occupied vehicle,
no injuries reported
2021: Unoccupied
vehicle
2021: Pedestrian fatality
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2021: Pedestrian fatality
2019: Unoccupied
vehicle
2018: Occupied vehicle;
no injuries reported
2017: Unoccupied
vehicle
2017: Unoccupied
vehicle
2017: Occupied vehicle;
no injuries reported
no injuries reported
2016: Unoccupied
vehicle
2016: Occupied vehicle;
1 injury reported
2015: Occupied vehicle,
no injuries reported
2019: Unoccupied
vehicle
2018: Unoccupied
vehicle
2018: Unoccupied
vehicle
2017: Unoccupied
vehicle
2016: Occupied vehicle,
fatality reported
2015: Pedestrian fatality
Crossing Improvements – Basis of Design
• Feasibility of Wayside Horns (WSH)
o The City would like to discuss the potential use of WSH as an interim measure or as an alternative to a four-quadrant gate system.
• Caltrain does not currently have wayside horns on the corridor. o Installation of WSH does not preclude train operators from sounding their horn any situation where the train operators feels it is warranted. • Caltrain noted that any roadway work or construction on the corridor would require train operators to sound their horns regardless of quiet zone status or installation of WSH.
o Caltrain noted this would not decrease the noise experienced by those in the vicinity of the crossing.
• Consultant team agreed, but pointed out that the spread of noise from a moving train horn is larger than a WSH, since the WSH would be a static object.
o Caltrain noted installation of a WSH would still require an encroachment permit.
Caltrain would want to see how a WSH integrates with their current systems. o Caltrain noted that a WSH may need an indicator light to alert train operators whether the WSH is operating or not.
o City requests Consultant team show an optional WSH alternative. o The FRA noted that from 2017-2024, there have been 21 strikes across these crossings. If WSH are installed, what stops people from being hit? • The City and Caltrain are undergoing trespass fencing enhancements through a separate project.
• Churchill Avenue
o Refresh pavement markings and upgrade warning signage to be compliant with 11th Edition MUTCD.
▪ Inclusion of W10-9P signs (NO TRAIN HORN) to all W10-1 posts. o Section 130 improvements are under construction. This includes upgrading warning devices and installation of a pre-signal.
o Due to location of pre-signal foundation on 100% plans, exit gate is shown as located downstream of mast arm.
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▪ CPUC and FRA noted they would need to bring this configuration to their larger teams for confirmation that this is acceptable.
o The City noted that their constituents may not be supportive of the pedestrian gate in the SW quadrant being shortened, given the high volume of pedestrians and bicyclists in the area. City may request the pedestrian infrastructure being pushed down the corridor further in order to accommodate the exit gate. o Caltrain asked the City if there has been any consideration for restricting trucks, at least for the southbound direction? Caltrain noted there have been several instances of broken gates and the SB entry gate being struck by vehicles making the right turn from Alma Street to Churchill Avenue.
▪ City noted restricting Caltrans Legal Design Vehicle may not be possible due to CVC regulations. As part of the project, we can review the existing truck routes and appropriate signage can be installed for truck turning restrictions. ▪ Consultant team will evaluate turning templates at this intersection and present the results to the diagnostic team.
• CPUC noted the truck turning templates may be requested for any future GO 88-B applications.
• Meadow Drive
o Refresh pavement markings and upgrade warning signage to be compliant with 11th Edition MUTCD.
▪ Inclusion of W10-9P signs (NO TRAIN HORN) to all W10-1 posts. o Caltrain noted the concepts say “Meadow Drive”. The roadway is listed as “East Meadow Drive” in inventory forms. Consultant team to update concepts to reflect correct roadway name.
o Caltrain noted that the handrailing could be brought closer to the tracks, rather than terminating at the beginning of the tactile warning strip. The Consultant team terminated the railing further from the track due to the proximity to the gates and counterweights. Caltrain noted that they are not concerned with the location of the counterweight and the fencing, as the counterweight is only active during a train event. ▪ Consultant team to modify handrailing to terminate 15’ from centerline of nearest track.
• Charleston Road
o Refresh pavement markings and upgrade warning signage to be compliant with 11th Edition MUTCD.
▪ Inclusion of W10-9P signs (NO TRAIN HORN) to all W10-1 posts. o Charleston Road was recently obligated Section 130 funds for a similar scope of work as Churchill Avenue. The City has selected a consultant for the design phase. ▪ Note that Section 130 will not fund Quiet Zone improvements, but will allow for spatial provisions for future quiet zone improvements. o Due to the Section 130 project likely advancing prior to any Quiet Zone improvements, much of the infrastructure upgrades are assumed to be part of the Section 130 program. o Caltrain noted the gates at this crossing (and the others) will likely need to be articulated due to needing to maintain clearances to the OCS. ▪ If the height of the gate tip when upright is longer than 22’, the gates will need to be articulated.
▪ This is due to NFPA 70E.
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Field Diagnostic Meeting - Palo Alto, California
October 22nd, 2024
Field Meeting Attendees:
Name Agency/Company Email
Ripon Bhatia City of Palo Alto [email protected] Ade Sogbesan CPUC [email protected]
Eric Walker FRA [email protected]
Lou Tolentino Caltrain [email protected]
Rick Bartholomew Caltrain [email protected]
Janet Wang JPB/Caltrain [email protected]
Amanda Zerbe TASI/Caltrain [email protected]
Fred Sandoval TASI/Caltrain [email protected]
Shawn Lima JPB/Caltrain [email protected]
Blake Silkwood Design/ Kimley-Horn [email protected] Taylor Brown Design/ Kimley-Horn [email protected]
Existing Conditions/General Crossing comments:
Preliminary Discussion/Existing Conditions:
• The Diagnostic Team noted that all crossing signage and pavement markings should consider the current MUTCD.
o W10-1 sign for all crossings should be 36”.
o W48(CA) sign showing number of tracks at the crossing should be provided at the W10-1s.
o Pavement marking should be refreshed if they are either faded or missing. o “CAUTION” signs are nonstandard and should be removed wherever present. • Existing vegetation should be removed or trimmed if obscuring visibility of the crossing traffic control devices as on-going maintenance items.
• Caltrain noted the need for Vehicle Presence Detection (VPD) with exit gates. • During construction, a contractor shall maintain an ADA pathway. • When construction activities are near a school, the contractor should be mindful to schedule work activities during times when there will likely not be students present. o It has been suggested to begin work after the school day begins, and end work before the school day ends.
Crossings included in Diagnostic Meeting
Crossing Roadway Name DOT# Roadway Authority Railroad Owner / Primary Operator Churchill Avenue 754998E City of Palo Alto JPB/Caltrain East Meadow Drive 755010S City of Palo Alto JPB/Caltrain Charleston Road 755011Y City of Palo Alto JPB/Caltrain
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Diagnostic Team Review and Recommendations by Location:
Crossing Location: Churchill Avenue, DOT 754998E, on October 22, 2024 at 10:00am.
General Crossing Comments:
• Caltrain noted construction activities from the Section 130 project have created tripping hazards in two quadrants. Caltrain requests the City coordinate with the Section 130 contractor as soon as possible to have the trip/fall hazards remedied.
• Existing entry gates are not articulated. This is due to vehicle strikes breaking the gates. Non- articulated gates were all that was readily available. Articulated gates to be reinstalled once Caltrain receives them.
Location 1:
• Quiet Zone project does not propose any improvements to this quadrant. • CPUC noted the “CAUTION” signs affixed to the W10-1/W48(CA) sign post is nonstandard and should be removed as an immediate action item.
Immediate action items:
1. City to trim vegetation blocking visibility of flashing light pairs and existing W10-1/W48(CA) signage.
2. City to remove nonstandard “CAUTION” signs affixed to the W10-1/W48(CA) sign post.
Location 2:
• The pre-signal foundation has been poured, and it placed further north of the tracks than shown Item 7
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on the approved construction drawings. Based on visual observations, it appears the exit gate can be placed between the tracks and the pre-signal mast arm and still remain parallel to the entry gate.
o The Consultant team will evaluate the photographs taken in the field and show the pre- signal mast arm as placed as it does in the field. Consultant team will update exit gate location accordingly.
Immediate action items:
1. City to coordinate with Section 130 contractor to remedy trip/fall hazard in this quadrant.
Location 3:
• Quiet Zone project does not propose any improvements to this quadrant. • Caltrain noted an additional trip hazard in this location.
Immediate action items:
1. City to coordinate with Section 130 contractor to remedy trip/fall hazard in this quadrant.
Location 4:
• Caltrain noted the exit gates could employ square weights (rather than oblong) to reduce the length of the counterweight. Square weights would reduce the length of counterweight from
4.5’ to approximately 3’.
• From visual observation, it appears the exit gate could be placed such that the detectable warning surface and pedestrian gates do not require relocation. o Consultant team to evaluate if this is feasible and provide updated design to Diagnostic Team.
• CPUC noted the existing curb is not 6” in height. CPUC recommended the curb lines be reconstructed to a 6” height.
Immediate action items: N/A
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Diagnostic Team Review and Recommendations by Location:
Crossing Location: East Meadow Drive, DOT 755010S, on October 22, 2024 at 11:00am.
General Crossing Comments:
• Diagnostic Team noted the existing pedestrian gates in Locations 1 and 3 require upgrades to have flashing light pairs.
Location 1:
• Quiet Zone project proposes to reconfigure sidewalk to relocate the pedestrian gate arm to 15’ from near track centerline.
o Diagnostic Team noted that existing sidewalk infrastructure could likely be maintained. • Existing pedestrian gate to be upgraded in place to include flashing light pairs and a bell. • CPUC inquired as to how the pedestrian gate flashers will be visible to oncoming pedestrians, given the sidewalk angle, vegetation, and other existing infrastructure. o Consultant team noted the front-facing flashers could be angled toward the sidewalk approach to be more visible for pedestrians.
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• Diagnostic Team noticed existing vegetation obstructs the visibility of the W10-1/W48(CA) sign post.
o CPUC noted the “CAUTION” signs affixed to the W10-1/W48(CA) sign post is nonstandard and should be removed as an immediate action item. • FRA noted the existing limit line is not placed 8’ from the nearest RRTCD, and should be shown as relocated.
o Consultant team to revise design.
Immediate action items:
1. City to trim vegetation blocking visibility of flashing light pairs and existing W10-1/W48(CA) signage.
2. City to remove nonstandard “CAUTION” signs affixed to the W10-1/W48(CA) sign post.
Location 2:
• Quiet Zone proposes sidewalk reconfiguration to accommodate exit gate. • From visual observation, it appears the exit gate could be placed such that the detectable warning surface and pedestrian gates do not require relocation. o Consultant team to evaluate if this is feasible and provide updated design to Diagnostic Team.
• Caltrain indicated gate arm foundations to be installed in a material that is easily removable for maintenance purposes. A 1’ buffer surrounding the visible foundation, backfilled with pea gravel or equivalent, is preferred to allow for access to maintain the equipment. This is particularly important for the exit gates due to needing island radar.
Immediate action items: N/A
Location 3:
• Quiet Zone proposes to upgrade existing pedestrian gate to include flashers. • CPUC inquired into the ability to provide a 2’ wide median between the railroad tracks and the Alma Street intersection.
o Consultant team to evaluate turning templates with a school bus for right- and left-turns from Alma Street onto East Meadow Drive.
Immediate action items: N/A
Location 4:
• From visual observation, it appears the exit gate could be placed such that the detectable warning surface and pedestrian gates do not require relocation. o Consultant team to evaluate if this is feasible and provide updated design to Diagnostic Team.
Immediate action items: N/A
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Diagnostic Team Review and Recommendations by Location:
Crossing Location: Charleston Road, DOT 755011Y, on October 22, 2024 at 12:00pm.
General Crossing Comments:
• N/A
Location 1:
• Quiet Zone proposes to replace the pedestrian gate device to include flashers. o Upon further discussion, this will be removed from the Quiet Zone scope and coordinated through the Section 130 project. The Section 130 project has funding and will likely be constructed prior to Quiet Zone improvements. In the interest of pedestrian safety, having these gates be replaced through Section 130 accelerates the timeline of installation.
• Diagnostic Team witnessed vehicles obeying the R10-6 (“STOP HERE ON RED”) signage, then advancing through the crossing and stopping in the hashed area downstream of the tracks. This was primarily observed for vehicles making a northbound right turn onto Alma. o Diagnostic Team recommended installation of a static R13-A (“NO RIGHT ON RED”) sign below the R10-6 sign to deter vehicles from queueing downstream of the tracks.
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• CPUC noted the “CAUTION” signs affixed to the W10-1/W48(CA) sign post is nonstandard and should be removed as an immediate action item.
• CPUC also noted the W10-1 sign is placed in close proximity to a tree, such that the tree appears to be growing around the sign face. City to remedy.
Immediate action items:
1. City to remove nonstandard “CAUTION” signs affixed to the W10-1/W48(CA) sign post.
2. City to remedy W10-1 sign face with tree growing around it.
Location 2:
• Quiet Zone proposes to install an exit gate and realign handrailing, allowing for provisions for a pre-signal mast arm foundation (which will be installed through the Section 130 project). • CPUC recommended the City remove the speed limit sign affixed to the existing traffic signal mast arm, and replace with a R13-A sign.
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• Caltrain noted the existing “STOP HERE” pavement markings on the sidewalk approach appear to be fading. Caltrain will coordinate with their maintenance groups and have the marking refreshed.
Immediate action items: N/A
Location 3:
• Quiet Zone proposes to upgrade existing pedestrian gate to include flashers. o Upon further discussion, this will be removed from the Quiet Zone scope and coordinated through the Section 130 project. The Section 130 project has funding and will likely be constructed prior to Quiet Zone improvements. In the interest of pedestrian safety, having these gates be replaced through Section 130 accelerates the timeline of installation. • Caltrain noticed the existing power pole appears to not have sufficient backfill to create a level surface. While this area is channelized and there should be no pedestrians, it still is a trip/fall hazard and should be remedied.
o Caltrain to coordinate with the City and PG&E on responsibility to perform this work.
Immediate action items:
1. Caltrain to coordinate with City and PG&E to have the trip/fall hazard remedied.
Location 4:
• From visual observation, it appears the exit gate could be placed such that the detectable warning surface and pedestrian gates do not require relocation.
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o Consultant team to evaluate if this is feasible and provide updated design to Diagnostic Team.
• Existing W10-/W48(CA) sign and post to be removed from this quadrant. Sign faces EB motorists and is nonstandard.
Immediate action items:
1. City to remove W10-1/W48(CA) on north side of roadway facing EB motorists.
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City Council
Staff Report
From: City Manager
Report Type: ACTION ITEMS
Lead Department: Planning and Development Services
Meeting Date: November 10, 2025
Report #:2504-4532
TITLE
REINTRODUCED FIRST READING: Adoption of an Ordinance Updating Palo Alto Municipal Code (PAMC) Section 18.40.250 (Lighting) of Chapter 18.40 (General Standards and Exceptions) and Amending Chapters 18.10, 18.12, 18.28, and Section 18.40.230 of Title 18 (Zoning) to Adopt New Outdoor Lighting Regulations; CEQA Status — Exempt pursuant to CEQA Guidelines Section 15308 (Actions for Protection of the Environment)
RECOMMENDATION
Staff recommend the City Council adopt the Draft Ordinance updating Palo Alto Municipal Code (PAMC) Section 18.40.250 (Lighting) of Chapter 18.40 (General Standards and Exceptions) and Amending Chapters 18.10, 18.12, 18.28, and Section 18.40.230 of Title 18 (Zoning) to adopt new outdoor lighting regulations.
EXECUTIVE SUMMARY
The draft Lighting Ordinance (Attachment A) implements part of one of the City Council’s priorities (No. 18, Council consideration of an ordinance implementing Bird Safe Glass & Wildlife Light Pollution Protections standards) and is consistent with Comprehensive Plan policies (including Policies N-1.9, N-3.3, and N-7.5). The draft ordinance, which has been modified based on City Council direction on April 7, 2025, aims to reduce light pollution and align with Dark Sky principles in order to increase the health and well-being of Palo Alto residents, protect wildlife and natural ecosystems, and reduce light pollution. The City Council’s direction at the April hearing aligned with the Planning and Transportation Commission (PTC) recommendations from October 2024, including requiring that new standards apply to replacement of existing lighting; allowing additional exceptions; and increasing efforts to raise awareness, which may help reduce the number of complaints and reliance on code enforcement. In addition, the City Council requested that requirements be included for already- installed existing lighting to comply with the new lighting standards after a set time period.
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The City does not have sufficient resources to proactively enforce the ordinance; staff will respond to egregious violations as capacity allows and will rely on outreach and community- based compliance measures to support implementation.
BACKGROUND
Early this year, Council identified 2025 City Council Priorities and Objectives. Under the Climate Action & Adaptation, and Natural Environment (CA) category, the City Council directed staff to prepare an ordinance implementing wildlife light pollution protections standards (2025 Council Priority #18).
Lighting and DarkSky International
The term “dark sky” generally refers to movement and achievement of significant reduction in light pollution so that the sky returns or becomes closer to its natural nighttime darkness.
Jurisdictions can implement regulations to decrease light pollution, and many cities have adopted “dark sky” ordinances to reduce light pollution. Advocates of “dark sky” policies cite a number of advantages, including:
1. Support of the body’s natural circadian rhythm, promoting better sleep.
2. Reduction of glare, improving safety and comfort at night.
3. Protection of nocturnal species, who rely on natural darkness for navigation, mating cycles, and foraging.
4. Support of plant cycles, which rely on periods of light and darkness.
5. Conservation of energy, by only using what light is necessary.
6. Reduction of light pollution, enhancing the beauty of the night sky.
DarkSky International is a recognized worldwide authority combatting light pollution.1 The organization publishes guidance for communities seeking to achieve a “dark sky” and decrease light pollution. The framework focuses on principles, which have been incorporated into the proposed ordinance:
1. Useful: Use light only if it is needed. All light should have a clear purpose. Consider how the use of light would impact the area, including wildlife and their habitat.
2. Targeted: Direct light so it falls only where needed. Use shielding and careful aiming to target the direction of the light beam so that it points downward and does not spill beyond where it is needed.
3. Low Level: Light should be no brighter than necessary. Use the lowest light level required. Be mindful of surface conditions, as some surfaces may reflect more light into the night sky than intended.
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4. Controlled: Use light only when it is needed. Use controls such as timers or motion detectors to ensure that light is available when it is needed, dimmed when possible, and turned off when not needed.
5. Warm-colored: Use warmer color lights where possible. Limit the amount of shorter wavelength (blue-violet) light to the least amount needed.
Previous City Council Discussion
On April 7, 2025,3 staff presented its recommendation for the Lighting Ordinance update, which differed from the Planning and Transportation Commission’s recommendation of October 30, 2024. Staff clarified that its recommendations primarily centered around concerns regarding impacts on enforcement and implementation once adopted. After deliberation, the City Council directed staff to return with several modifications, including requiring that new standards apply to replacement of existing lighting; allowing additional exceptions; and increasing efforts to raise awareness. These modifications aligned with most of the PTC recommendations and included requirements to be applied to all existing lighting, similar to the City of Brisbane. The City Council motion and staff analysis is provided below.
ANALYSIS
On April 7, 2025, the City Council directed staff to revise the draft ordinance for greater consistency with the recommendations made by the Planning and Transportation Commission in October 2024. The City Council’s motion items are italicized below, and staff descriptions on how each was incorporated into the draft ordinance follow each element of the motion:
MOTION:
A. Ensure protections in the existing code are not eroded for existing outdoor lighting in all zoning districts.
a. Retain the Requirements and Guidelines that the current municipal code provides to riparian ecosystems section 18.40.140.
No revisions needed as the updated ordinance provides equivalent or greater protection from light pollution compared to the existing outdoor lighting requirements. Additionally, the existing provisions and requirements in PAMC
18.40.140 will remain until the Stream Corridor Protection Ordinance Update is adopted.
B. Require this ordinance apply to all new or replacement outdoor lighting consistent with the Planning and Transportation Commission (PTC) motion of October 30th to include:
3 Link to the City Council agenda for the public hearing on April 7, 2025 (Item #17):
https://cityofpaloalto.primegov.com/Portal/Meeting?meetingTemplateId=16024 Item 8
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a. Installation of new outdoor lighting, replacement of existing outdoor lighting fixtures, or changing the lighting type or system;
Incorporated in Section 18.40.250(c). The language from the motion was added to the applicability section.
b. for replacement lighting fixtures on buildings and structures, develop a hardship exception provision that would consider technical feasibility or financial burden to only apply to replacements on existing buildings and structures; and Incorporated in Section 18.40.250(j)(2). An exception can be requested if implementation of the lighting requirements more than doubles the cost of the project.
c. any existing nonconforming lighting after 10 years for residential and 5 years for nonresidential shall remain extinguished until brought into compliance with this ordinance.
Incorporated in Section 18.40.250(l). The deadline for existing lighting to comply with the new requirements is five years from the effective date of the ordinance for nonresidential zoning districts, and 10 years for residential and mixed-use zoning districts. Any existing lighting that has not been brought into compliance with the Code by these deadlines must remain extinguished (off) until it meets the new lighting standards.
C. Existing luminaires that have the technical capacity to be adjusted to comply with the ordinance without a need to change the fixture should comply within two (2) years of the effective date of the ordinance (i.e: fixtures that have existing dimmers, adjustable directionality, timers, Correlated Color Temperature adjusters, motion sensors, etc.).
Incorporated in Section 18.40.250(l)(2). The deadline for existing lighting to comply through use of existing features is two years from the ordinance's effective date. That lighting will be required to meet the new standards, with the exception of the shielding requirements.
D. Amend Section (4)(A) to include specific application of the curfew to all new, replacement, and existing outdoor luminaires.
a. Citywide and Holiday lighting curfew of midnight.
Incorporated in Sections 18.40.250(d)(4) and 18.40.250(e)(4). The lighting curfew provision was revised to extend the turn-off time of all outdoor lighting to 12:00 Item 8
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a.m. Additionally, the seasonal lighting exception language was revised to explicitly state when such lighting is subject to extinguishment.
E. Implement the October 30th PTC motion regarding light trespass to change the light trespass from 0.5 to 0.1 foot candles at every reference throughout the ordinance.
Incorporated throughout the ordinance.
F. Incorporate into Section 1.B. Findings and Declarations, and Section 2 (a) Purpose, the Five Principles for Responsible Outdoor Lighting. One of the sections should include the full language of the principles.
Incorporated (Section 1B of the ordinance, and Section 18.40.250(a)(1)).
G. Develop an exception for special security concerns.
An exemption has been incorporated in the draft ordinance (Section 18.40.250(d)(7)) to address this direction, however without use of “special security concerns.” See below for further discussion of the specific approach presented.
H. Staff to return with recommendations on compliance mechanisms that would reduce the need for code enforcement – such as self-certification under business licenses, education through Utilities inserts, and potential adoption of a tool similar to Brisbane’s Good Neighbor Letter.
Potential measures are explained below for the City Council consideration, along with the pros and cons for each measure.
Exception for Special Security Concerns
During the April hearing, the City Council heard concerns from a community member about how the proposed new lighting standards might impact security, especially in their neighborhood along Edgewood Drive. A speaker noted that less or limited lighting could worsen existing security concerns for property owners in the neighborhood. In response, the City Council asked staff to look into allowing an exception for properties with heightened security concerns.
Staff worked with the City’s Police Department and reviewed crime information from the past year for areas near the San Francisquito Creek. While the information showed that crimes and calls for service do occur in this area, they were not significantly higher in the specific residential neighborhood mentioned compared to other areas of the City. The Police Department also confirmed that the City currently does not have any areas identified as having Item 8
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special concerns due to high crime rates, and there are not areas in Palo Alto that they would characterize as “high crime.” While crime data do not support the designation of specific areas as high security risk zones, staff recognize some residents may have heightened perceptions of safety concerns based on local conditions or experiences.
The Edgewood neighborhood does have unique characteristics that could justify different lighting standards including proximity to the creek, lot arrangements, and bordering another jurisdiction. As a result, to implement the Council’s direction, staff have included an exemption in the draft ordinance specific to the Edgewood neighborhood. While the draft ordinance currently exempts this neighborhood from the new outdoor lighting standards, the curfew requirement would still apply to the neighborhood, unless otherwise directed by the City Council.
Measures to Support Compliance
The City does not have sufficient resources to proactively enforce the new outdoor lighting ordinance. While staff will respond to egregious violations as capacity allows, most violations are expected to occur outside of typical Code Enforcement hours (i.e., at night), and staff are already managing a full caseload of other enforcement matters. Additionally, the compliance timelines established in the ordinance, as directed by the City Council, are unlikely to result in full compliance within the specified periods.
Staff remain concerned about establishing regulatory standards that cannot be reliably enforced, as this may lead to unrealistic expectations in the community regarding the extent of compliance that can be achieved.
Recognizing these challenges, the City Council directed staff to explore additional options to support a community-based approach to compliance. The following measures are not part of the ordinance itself but could be implemented after the ordinance is adopted:
Neighbor Letter Template: A letter template modeled on tools used by the City of Brisbane and DarkSky International could allow residents to inform neighbors about the ordinance and encourage voluntary compliance. While this may reduce initial complaints to the City, it relies on voluntary action and may lead to disputes or unprioritized reports.
Educational Materials: Staff will develop outreach materials, including online content, printed handouts, and utility bill inserts, to raise awareness about the new requirements. This approach aims to reduce inadvertent non-compliance through public education but has no direct enforcement effect and depends on public engagement. Affidavit Letter: Staff considered requiring applicants and property owners to sign an affidavit acknowledging awareness of the lighting requirements during the permit process. However, this approach would duplicate information already reviewed as part Item 8
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of plan review and introduce additional regulatory steps to the permitting process, and is therefore not recommended.
These supplemental efforts are intended to promote broader awareness and voluntary compliance in the absence of dedicated enforcement resources.
Additional Minor Changes
To reduce redundancy, the Outdoor Security Lighting requirements previously found under the Special Purpose Lighting section were removed. These requirements largely duplicated the citywide outdoor lighting standards.
POLICY IMPLICATIONS
The Lighting Ordinance Update aligns with the Comprehensive Plan’s Natural Environment Element, which aims to preserve natural resources through sustainable practices and climate adaptation. Policy N-7.5 seeks to minimize light from development, Policy N-1.9 mandates shielding exterior lighting in foothills, and Program N3.3.3 requires the careful design of lighting surrounding natural riparian corridors. The ordinance improves nighttime visibility for wildlife, enhances energy efficiency and supports environmental protection and community health goals.
While not directly related to the Palo Alto Sustainability Climate Action Plan (S/CAP), the ordinance supports the goal of enhancing ecological resilience. It provides better habitats for nocturnal wildlife, aiding environmental conservation. Although not a specific S/CAP goal, the ordinance may reduce electricity usage, as outdoor lighting will have motion sensor controls, thus fostering sustainability and supporting S/CAP objectives.
Under Program 3.2 of the Housing Element, the City must analyze how new regulations impact housing production. The Lighting Ordinance is not expected to significantly affect housing, as it doesn't change density, layout, or height. Minor cost or design modifications may be needed for compliance, but dark sky products and lighting technologies are available.
FISCAL/RESOURCE IMPACT
Staff anticipate a misalignment in the community’s expectations to enforce this ordinance relative to existing code enforcement workload and resources. Except for documented isolated and egregious violations of the ordinance, staff will rely on low-cost supplemental measures such as a letter template that can be used between neighbors and potential educational materials to inform the community about requirements and standards.
STAKEHOLDER ENGAGEMENT
Staff conducted two study sessions, one in February and another in July 2024 through the ARB to provide a forum for community members to express their views and concerns regarding the proposed ordinance. In addition, staff have engaged with representatives from the Santa Clara Item 8
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Valley Audubon Society and Sierra Club Loma Prieta Chapter to solicit their input on the proposed ordinances.
On October 8, 2025, Staff conducted a focused outreach meeting with Palo Alto businesses and presented draft ordinance. A total of 38 participants attended this focused outreach meeting that was held virtually, and the participants included members of the Palo Alto Chamber of Commerce, Stanford University, and businesses/developers of Stanford lands. Several attendees expressed concerns about the requirement to bring all existing lighting up to the new standards, which could require expensive investments to completely redesign lighting plans.
Other members were concerned about safety implications of reducing lighting at commercial facilities that have overnight operations, noting specifically that Federal Occupational Safety and Health Administration (OSHA) workplace regulations would require lighted walkways, for example. The requirement for existing lighting to comply with the new lighting regulations in the ordinance was directed by the City Council at the April 7, 2025, meeting; as a result this requirement remains in the draft ordinance. However, the ordinance does include exceptions for lighting at building entrances, parking areas, walkways, and driveway areas, and safety requirements in Federal or State law (including OSHA regulations) will supersede this ordinance where required. The outreach meeting materials, including the staff presentation and recorded meeting, are available on the project website at www.PaloAlto.gov/OutdoorLighting.
Staff received numerous comment letters from the Santa Clara Valley Bird Alliance (formerly known as the Santa Clara Valley Audubon Society) and Sierra Club Loma Prieta Chapter on various versions of the draft ordinance presented to the ARB and PTC. These comments were considered and incorporated into draft ordinance throughout the process. The latest ordinance reflects many of the suggestions received.
At the time of staff report preparation, staff received one comment letter from a resident of Crescent Park. While supporting responsible outdoor lighting, the resident is opposed to the proposed Lighting ordinance update due to its overly restrictive nature, negative impact on safety, and lack of sufficient community input.
All public comments received for the draft lighting ordinance are in Attachment B.
Future Outreach
PTC recommended to the 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. Unless directed otherwise, staff will inform the project’s interested parties about the ordinance adoption and provide a copy for review. Staff will also prepare information to be shared on the City’s website and at the Development Center regarding the new regulations and communicate as appropriate through other City communication channels. The City Council could also consider additional regulations for interior commercial lighting at future priority-setting sessions.
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ENVIRONMENTAL REVIEW
The City has reviewed these proposed ordinances in accordance with that authority and criteria set forth in the California Environmental Quality Act. The City, as the lead agency, anticipates that these ordinances will be exempt from CEQA in accordance with CEQA Guidelines Section 15308, which includes actions by regulatory agencies for the protection of the environment.
ATTACHMENTS
Attachment A: Draft Ordinance Updating Lighting Standards (PAMC Section 18.40.250) Attachment B: Examples of Educational Materials and Template Neighbor Letters Attachment C: Public Comments received after the City Council hearing on April 7, 2025 APPROVED BY:
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Ordinance No. _____
Ordinance of the Council of the City of Palo Alto Repealing and Replacing Section
18.40.250 (Lighting) of Chapter 18.40 (General Standards and Exceptions) and Amending Chapters 18.10, 18.12, 18.28 and Section 18.40.230 of Title 18 (Zoning) of the Palo Alto Municipal Code to Adopt New Outdoor Lighting Regulations
The Council of the City of Palo Alto ORDAINS as follows:
SECTION 1. Findings and Declarations. The City Council finds and declares as follows:
A. The term “dark sky” generally refers to achievement of significant reducƟon in light polluƟon so that the sky returns or becomes closer to its natural nighƫme darkness.
B. Adhering to Dark Sky principles, which promote responsible outdoor lighƟng pracƟces, can significantly reduce light polluƟon and miƟgate its harmful effects. These principles emphasize using light only if it is needed, direcƟng so that it falls only where it is needed, having lighƟng only when it is necessary and no brighter than necessary, and using warmer lights.
C. On January 29, 2024, the City Council selected four City Council prioriƟes, one of which is the Climate Change & Natural Environment – ProtecƟon & AdaptaƟon, and included an objecƟve to “approve a bird safe glass and wildlife light polluƟon protecƟons ordinance.”
D. On February 14, 2024, and July 18, 2024, the Architectural Review Board conducted study sessions and provided feedback on the concepts of the DarkSky regulaƟons and draŌ ordinance.
E. On August 14, 2024, the Planning and TransportaƟon Commission reviewed the draŌ ordinance, provided feedback and recommended that staff return with more informaƟon, conƟnuing the hearing to a date uncertain.
F. On October 30, 2024, the Planning and TransportaƟon Commission recommended that City Council adopt the ordinance.
G. The ordinance aligns with Dark Sky principles and is intended to reduce light polluƟon at night, protecƟng wildlife and supporƟng a sustainable and resilient community.
SECTION 2. Section 18.40.250 (Lighting) of Chapter 18.40 (General Standards and Exceptions) of Title 18 (Zoning) of the Palo Alto Municipal Code is repealed in its entirety and replaced with a new Section 18.40.250 (Lighting) to read as follows:
18.40.250 Lighting
(a) Purpose. The intent of this section is to establish exterior lighting standards to reduce light pollution. Exterior lighting of parking areas, pathways, and common open spaces, including fixtures on building facades and free-standing lighting should aim to:
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(1) Reduce light pollution and its adverse effects on the environment, wildlife habitat, and human health through implementing Dark Sky Principles of responsible outdoor lighting that are useful, targeted, low level, controlled, and warm colored; (2) Minimize the visual impacts of lighting on abutting or nearby properties and from adjacent roadways;
(3) Provide safe and secure access on a site and adjacent pedestrian routes; (4) Achieve maximum energy efficiency; and
(5) Complement the architectural design of the project. (b) Definitions. For purposes of this chapter, the following words and phrases are defined as follows:
(1) “Correlated Color Temperature” or “Color Temperature” means a specification of the color appearance of the light emitted by a light source, measured in Kelvin (K).
Warmer color temperatures are a lower number, and cooler color temperatures are a higher number.
(2) “Fully Shielded” means a luminaire constructed and installed in such a manner that all light emitted, either directly from the lamp or a diffusing element, or indirectly by reflection or refraction from any part of the luminaire, is projected below the horizontal plane extending from the bottom of the lamp. (3) “Glare” means light entering the eye directly from a luminaire or indirectly from reflective surfaces that causes visual discomfort or reduced visibility to a person. (4) “Lamp” means, in generic terms, a source light, often called a “bulb” or “tube.” Examples include incandescent, fluorescent, high-intensity discharge (HID) lamps, and low-pressure sodium (LPS) lamps, as well as light-emitting diode (LED) modules and arrays.
(5) “Light pollution” means the material adverse effect of artificial light, including, but not limited to, glare, light trespass, sky glow, energy waste, compromised safety and security, and impacts on the nocturnal environment, including light sources that are left on when they no longer serve a useful function.
(6) “Lumen” means the common unit of measure used to quantify the amount of visible light produced by a lamp or emitted from a luminaire (as distinct from “Watt,” a measure of power consumption).
(7) “Luminaire” means outdoor illuminating devices, lamps, and similar devices, including solar powered lights, and all parts used to distribute the light and/or protect the lamp, permanently installed or portable.
(8) “Seasonal lighƟng” means lighƟng installed and operated in connecƟon with holidays or tradiƟons within the Ɵme period specified in SecƟon 18.40.250(d)(4). String Item 8
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lighƟng used outside these periods is not considered seasonal lighƟng and shall be subject to requirements in SecƟon 18.40.250(f)(6).
(9) “String lighting” means light sources connected by free-strung wires or inside of tubing resulting in several or many points of light.
(c) Applicability. Except as otherwise provided in subsections (d) and (e)(4)(A) below, the outdoor lighting standards and guidelines set forth in this Section shall apply to the following projects:
(1) All newly constructed structures and buildings; or
(2) Structures or buildings proposing a Substantial Remodel, as defined in Section
16.14.070; or
(3) If a building permit is required: New installation of outdoor luminaires, replacement of existing outdoor luminaires, or modifications to the lighting type or system. (4) All existing outdoor light fixtures installed prior to the effective date of this ordinance shall conform to the provisions of this ordinance according to the compliance schedule set forth in Section 18.40.250(l).
(d) Exemptions. The following types of lighting are exempt from the lighting requirements of the section:
(1) Illuminated street numbers;
(2) Temporary construction or lighting for emergency personnel; (3) Lighting authorized by a special event, special or temporary use permit; (4) Seasonal lighting, subject to extinguishment at 12:00 a.m., during the period of October 15 through January 15 of each year;
(5) Lighting for Airport Operations. Nothing in this section shall be interpreted to restrict, limit, or otherwise regulate lighting that, in the reasonable judgment of the Airport Manager, is prudent or necessary for airport operations, airport safety, or air navigation in connection with operations at the Palo Alto Municipal Airport; or (6) Lighting for Emergency Shelters. Lighting for emergency shelters shall be subject to PAMC 18.14.060.
(7) Single family residential sites adjacent to San Francisquito Creek and fronting on Edgewood Drive if the portion of the site subject to a permanent easement in favor of the Santa Clara Valley Water District (or its successor in interest) for flood control purposes is reconfigured after January 1, 2002. These sites shall be subject to the requirements under Section 18.40.250(e)(4)(A).
(e) Lighting Standards.
(1) Shielding
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(A) All outdoor lighting shall be fully shielded and directed to avoid light trespass. No lighting shall trespass more than 0.1-foot candle as measured at the property line.
(B) Exceptions for shielding requirements shall be applied to the following types of lighting:
(i) Low voltage landscape uplighting used to illuminate fountains, shrubbery, trees, and walkways, outdoor art or public monuments provided that they use no more than a 10-watt incandescent bulb or LED equivalent or emit no more than 150 lumens. These luminaires may not direct light towards the public right-of-way;
(ii) Sidewalk-facing lighƟng for zero lot line developments, provided the luminaires are motion-activated and automatically extinguish within five minutes without further activation; or
(iii) String lighting pursuant to Section 18.40.250(f)(5). (2) Parking Lot Lighting Height.
(A) Exterior lighting fixtures shall be mounted less than or equal to 15 feet from grade to top of fixture in parking lots in residential development and 20 feet in parking lots with commercial and mixed-use development. (3) Illumination Level and Color Temperature
(A) All light sources shall have a correlated color temperature of 2,700 Kelvin or less. (B) The maximum outdoor light intensity on a site shall not exceed an average value of 5 foot-candles.
(4) Lighting Control.
(A) Lighting Curfew. Unlike other provisions in this section, the Lighting Curfew shall apply to all outdoor luminaires for new and existing buildings and structures, unless otherwise approved. All outdoor lighting shall be fully extinguished or be motion sensor operated by 12:00 a.m., two hours after the close of business, or when people are no longer present in exterior areas, whichever is later. (B) All lighting activated by motion sensor shall be set up to extinguish after no more than five minutes without further activation.
(C) All lighting shall be automatically extinguished using a control device or system when there is sufficient daylight available, except for lighting under canopies or lighting for tunnels, parking garages, or garage entrances. (D) Exceptions for Lighting Control.
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(i) Any lighting at building entrances, parking areas, walkways, and driveways area;
(ii) Outdoor pathway lights that emit 25 lumens or less; or (iii) Lighting that illuminates a pedestrian pathway (examples include bollard, in-place step, or building mounted), provided that such lighting is a maximum height of four (4) feet above the pathway and fully shielded. (f) Special Purpose Lighting. The standards in this section shall prevail over any conflicting standard in subsection (e).
(1) Low Density Residential Lighting. In addition to the lighting standards in the section, the following lighting requirements shall be applicable to projects in R-1, R-2, RE, RMD, NV- R1, or NV-R2.
(A) When abutting any residential use, no spillover of lighting to adjacent properties shall be allowed.
(B) A maximum of 1,260 lumens shall be allowed for each fully shielded outdoor lighting. No more than 420 lumens shall be allowed for permitted non-shielded outdoor lighting.
(C) Skylights shall limit illuminance and glare during night hours. Glare shall be mitigated through the use of translucent glass, shading systems, and interior light placement.
Skylights shall not use white glass.
(D) Height for Recreational and Security Lighting. Free-standing lighting shall be a maximum of twelve feet (12’) in height for those that were installed on or after March 11, 1991.
(2) Athletic Facilities Lighting. Outdoor athletic facilities shall conform to the following standards:
(A) Field lighting is provided exclusively for illumination of the surface of play and viewing stands, and adjacent proximity areas for public safety. (B) Illumination levels shall be adjustable based on the task (e.g., active play vs. field maintenance).
(C) Off-site impacts of the lighting will be limited to the greatest practical extent possible.
(D) Lights shall be extinguished by 10:30 p.m. except when the facilities are being used for active play and maintenance before or after permitted events, and the lights are equipped with a timer.
(E) Timers that automatically extinguish lights shall be installed to prevent lights being left on accidentally overnight.
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(3) Automobile Service Station Lighting
(A) Lighting fixtures in the ceiling of canopies shall be fully recessed or mounted directly to the underside of the canopy. All luminaires shall be located so that no lighting is directed towards the adjoining property or public rights-of-way. (B) Luminaires are not permitted on top of the canopy fascia. (C) The maximum light intensity under the canopy shall not exceed an average foot- candle of 12.5, when measured at finished grade.
(D) No free-standing lighting shall be higher than 15 feet above finished grade. (E) The canopy fascia shall not be illuminated.
(4) Outdoor Space Above Ground Floor. These requirements apply to all outdoor spaces located above ground level, including, but not limited to, rooŌop gardens, rooŌop restaurants or bars, balconies, and decks.
(A) Any lighting shall be shielded from public views and any luminaires shall be fully shielded and no uplighting shall be permitted.
(B) Lights shall be dimmable to control glare and placed on timers to turn off after 10:00 p.m. or as permitted pursuant to Section 18.40.250(e)(4)(D) (C) No light trespass shall be allowed more than 0.1 foot-candle as measured beyond the perimeter of the roof deck or other outdoor space above the ground floor. (5) String Lighting.
(A) String lighting color temperature shall not exceed 2,700 Kelvin and no individual lamp that is part of a string lighting installation shall exceed a rating of 42 lumens.
No string lighting shall be blinking, flashing, or chasing. (B) For commercial and mixed-use areas, string lighting shall be limited to designated outside dining or display areas or common open space (i.e. courtyard or patio). (6) Parklets. Lighting for any parklets shall comply with the lighting standards established in the Permanent Parklet Program.
(g) Prohibited Lighting. The following types of lighting are prohibited except when used by emergency service personnel during an emergency:
(1) Outdoor lighting that blinks, flashes, or rotates; or (2) Searchlights, aerial lasers, or spotlights.
(h) Lighting for Signs. See Chapter 16.20 for lighting requirements for signs. (i) Additional Provisions and Conflict Precedence. Lighting required by the Building Code, Fire Code, or state or federal law shall additionally comply with the requirements of this section, Item 8
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unless these requirements necessarily conflict with the aforementioned Codes and laws. In the event of a conflict, the standards in the applicable Codes and laws shall prevail. (j) Hardship Exceptions. The Director may grant an exception from the requirements in Section
18.40.250, if a project applicant provides evidence demonstrating one of the following hardships:
(1) Implementation of the lighting requirements in this ordinance would impair the historical integrity and character-defining features of the building and create an adverse impact to the building’s historical, architectural, and cultural significance; or (2) Implementation of the lighting requirements in this ordinance would more than double the cost of the project. This exception shall apply only for replacement of existing outdoor luminaires or changing the lighting type or system that requires a building permit.
(k) Public Facilities. Public Facilities, including City-owned and operated facilities, shall comply with the outdoor lighting standards of this Section to the extent feasible. The Director may grant adjustments to any applicable lighting standards for such facilities if the adjustment is necessary for the efficient operation, maintenance, or safety of the facility, or to ensure public safety and security; and is consistent with the overall intent and purpose of this Section. A written request for an adjustment, including supporting documentation, shall be submitted and shall be reviewed according to the applicable review procedures in PAMC Section 18.77 associated with the proposed development. (l) Existing Nonconforming Lighting.
(1) Within two years of [the effective date of this ordinance]: Where existing outdoor luminaires have the ability to adjust (through existing dimmers, directional adjustability, timers, etc.), the requirements under Section 18.40.140(e), except for the shielding requirements under the subsection 18.40.140(e)(1), shall apply. (2) For all existing outdoor luminaires, the requirements under Section 18.40.140(e) shall apply within the following timeframes from [the effective date of this ordinance]:
(A) Residential and Mixed Use Zoning Districts: Within ten years. (B) Nonresidential Zoning Districts: Within five years. (3) Any nonconforming lighting still in place after the compliance deadline shall remain extinguished at all times until they are brought into compliance.
SECTION 3. Subsection (e) of Section 18.40.230 (Rooftop Gardens) of Chapter 18.40 (General Standards and Exceptions) of Title 18 (Zoning) of the Palo Alto Municipal Code is amended to read as follows (additions underlined; deletions struck-through):
(e) Any lighting shall be shielded from public views and have full cutoff fixtures that cast downward-facing light, or consist of low-level string lights; no up-lighting is permitted. Lights shall be dimmable to control glare and placed on timers to turn off after 10:00 p.m.
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Photometric diagrams must be submitted by the applicant to ensure there are no spillover impacts into windows or openings of adjacent properties.For lighting requirements, refer to Section 18.40.250.
SECTION 4. Subsection (g) of Section 18.10.040 (Development Standards) of Chapter
18.10 (Low Density Residential (RE, R-2 and RMD) Districts) of Title 18 (Zoning) of the Palo Alto Municipal Code is amended to read as follows (additions underlined; deletions struck-through):
(g) Lighting in R-2 District
In the R-2 district, recreational and security lighting shall be permitted only so long as the lighting is shielded so that the direct light does not extend beyond the property where it is located. Free- standing recreational and security lighting installed on or later than March 11, 1991, shall be restricted to twelve feet (12') in height. For lighting requirements, refer to Section 18.40.250.
SECTION 5. Subsection (k) of Section 18.12.040 (Site Development Standards) of Chapter 18.12 (R-1 Single-Family Residential District) of Title 18 (Zoning) of the Palo Alto Municipal Code is amended to read as follows (additions underlined; deletions struck-through):
(k) Lighting
Recreational and security lighting shall be permitted only so long as the lighting is shielded so that the direct light does not extend beyond the property where it is located. Free-standing recreational and security lighting installed on or later than March 11, 1991 shall be restricted to twelve feet (12') in height. Direct light from outdoor fixtures shall only fall on the walls, eaves, and yard areas of the site on which it is located. Outdoor fixtures shall have lens covers or reflectors that direct the light away from the neighboring properties. For lighting requirements, refer to Section 18.40.250.
SECTION 6. Subsection (n) of Section 18.28.270 (Additional OS District Regulations) of Chapter 18.28 (Special Purpose Districts) of Title 18 (Zoning) of the Palo Alto Municipal Code is amended to read as follows (additions underlined; deletions struck-through):
(n) Light and Glare
Exterior lighting should be low-intensity and shielded from view so it is not directly visible from off-site. The light emitted from skylights shall be minimal during the night hours. Utilizing treatments such as translucent glass, shading systems, and interior light placement can reduce the night glare. Skylights shall not use white glass. For lighting requirements, refer to Section
18.40.250.
SECTION 7. If any section, subsection, clause or phrase of this Ordinance is for any reason held to be invalid, such decision shall not affect the validity of the remaining portion or sections of the Ordinance. The Council hereby declares that it should have adopted the Ordinance and each section, subsection, sentence, clause or phrase thereof irrespective of the fact that any one or more sections, subsections, sentences, clauses or phrases be declared invalid.
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SECTION 8. The Council finds that this project is exempt from the provisions of the California Environmental Quality Act (“CEQA”), pursuant to Section 15061 of the CEQA Guidelines, because it can be seen with certainty that there is no possibility that the ordinance will have a significant effect on the environment and Section 15308, as an action by a regulatory agency to protect the environment.
SECTION 9. This ordinance shall be effective on the thirty-first day following its adoption.
SECTION 10. This Ordinance shall not apply to any project application deemed complete prior to the effective date of this Ordinance.
INTRODUCED:
PASSED:
AYES:
NOES:
ABSENT:
ABSTENTIONS:
NOT PARTICIPATING:
ATTEST:
____________________________ ____________________________ City Clerk Mayor
APPROVED AS TO FORM: APPROVED:
____________________________ ____________________________ Assistant City Attorney City Manager
____________________________
Director of Planning & Development
Services
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Have you heard? The City of Brisbane passed a “Dark Sky Ordinance” that regulates outdoor lighting.
You may not be aware of this, but your lights are:
too bright
shining in our window
interfering with our sleep
________________
________________
Please consider:
directing your lights downward
shielding the lamp
using a lower wattage bulb
using a “warmer” color temperature
using motion sensor and/or timer
________________
I would be willing to help with the cost and/or implementation of changes.
In addition to helping us out, these actions can help bring you into compliance with the City’s ordinance, reduce light pollution, and improve the environment.
Thanks so much for your time and understanding!
- your concerned neighbor
Learn more at brisbaneca.org/darksky
Adapted by OSEC from darksky.org/resources/what-is-light-pollution/light-pollution-solutions/lighting/my-neighbors-lighting/ Dear Neighbor...
Shielding reduces glare that can be dangerous and
unsafe. Glare can be blinding and create harsh
shadows where “bad guys” can hide. Shielded lighting
provides real security, not just the illusion of security, which I think we both want for our families and friends.
There are several other ways to improve lighting, save
money, and still be safe. One is using motion sensors,
which alert you if someone is in your yard after dark
and have the added benefit of reducing your electric
bills by keeping the lights off when they’re not needed.
Timers are another way to save money because these
devices turn off your lights when they’re not needed,
for example, when you retire for the night.
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[Date]
Dear [insert neighbor’s name],
I’m your neighbor [insert your name] at [address], and I would love to talk with you about good outdoor lighting. I notice that you have installed outdoor lights on your property, and I applaud your desire to help improve our neighborhood.
You may not have realized that some of your lights are a bit too bright and shine in [pick areas as they apply: our bedroom window, the backyard, into our house etc.] and interfere with our [sleep, hobbies, view of the sky, etc.]. I don’t wish to tell you what to do with your home, but I’m hoping we can openly discuss this and come to a compromise that fulfills and respects everyone’s needs.
Please understand I’m not asking you to remove the lights, but perhaps make subtle changes that will work for everyone.
One idea would be redirecting the light by shielding the fixtures so that they are even more effective. Unshielded lamps create dangerous glare — this glare causes harsh shadows which can blind you to real, hidden hazards such as unwanted visitors (see pictures below). On the other hand, shielded lighting provides real security (not just the illusion of security) which I think we both want for our homes. As an extra benefit, shielding a lamp usually involves a lower wattage bulb, which would be a money-saver on your electric bill.
There are several other ways to improve lighting, save money, and still be safe. One is using motion sensors, which alert you if someone is in your yard after dark, and also reduce your electric bills by keeping the lights off when not needed. Timers are another way to save money, since they can automatically turn off your outdoor lights when you go to bed.
Thank you so much for your time and understanding! I would love to talk with you about how I can help, and how lighting changes can benefit your safety, budget, and the night sky.
Sincerely,
[your name]
[contact info]
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Shielded lights protect the night.
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Protect
the night
Preserving and restoring the
natural nighttime environment is
more urgent than ever.
Light pollution continues to grow at an alarming
rate, harming our health, damaging the
environment, and diminishing our view of the stars.
DarkSky International has a plan to save the night,
but we need your help.
The stars are disappearing
Join the movement and help
save the night
DarkSky is a global community
working together to save the night.
Sign-up today for DarkSky e-news
updates to learn more.
DarkSky International is a U.S.-based 501(c)(3) nonprofit that supports a global community and movement
dedicated to preserving and protecting the natural
nighttime environment.
DarkSky International
5049 East Broadway Blvd #105
Tucson AZ 85711
USA
www.DarkSky.org
+1-520-293-3198
Light pollution isreversible!
Unlike other forms of pollution, light pollution is a
problem with solutions that are easy to implement.
These solutions deliver immediate and lasting
results.
SUCCESS STORY
In 2018, the City of Tucson,
Arizona, U.S.A. (population
500,000) upgraded its
streetlights. By doing so, it
saved $2.2 million per year in
energy costs and reduced
light pollution by 7%.
WE’RE MAKING AN IMPACT
1,000+
More than 1,000 DarkSky
Approved lighting fixtures are
available on the market.
2,000+
DarkSky supports more than
2,000 volunteer Advocates in
49 countries.
70+
DarkSky supports more than
70 chapters in 24 countries.
200+
More than 200 International
Dark Sky Places have been
certified, protecting over
160,000 sq km of dark places
around the globe.
Photo credit: Bin Chen
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Light pollution...
What is light pollution?
Light pollution is the human-made alteration of outdoor light levels from those occurring naturally. When we over-light, fail to use timers and sensors, or use the wrong color of light, we negatively affect many parts of our world.
Destroys critical wildlife habitat
Plants and animals depend on
Earth’s daily light and dark
cycle to govern life-sustaining
behaviors. Research shows
that artificial light at night has
adverse and even deadly
effects on many species.
Wastes energy and money
Most outdoor lighting is
wasted. This energy waste
increases greenhouse gas
emissions contributing to
climate change and wastes
billions of dollars each year.
Harms human health
Studies indicate that artificial
light at night negatively affects
human health by increasing
our risks for obesity, sleep
disorders, depression,
diabetes, breast cancer, and
more.
Decreases safety and security
There is no clear scientific
evidence that increased
outdoor lighting deters crime.
In fact, glare from unshielded
streetlights can decrease
personal safety, contributing
to both crime and accidents.
Robs us of our night sky heritage
Our ancestors experienced a
night sky that inspired science,
religion, philosophy, art, and
literature. Now, millions of
children across the globe will
never know the wonder of
seeing the Milky Way.
Inhibits scientific research
Satellites in low Earth orbit
create visible trails in the night
sky, inhibiting astronomical
research and jeopardizing
NASA’s early warning system
for asteroid collisions.
What can I do?
DarkSky’s Five Principles for Responsible
Outdoor Lighting can help you make smart
choices to reduce light pollution. Do your
lights protect the night?
All light should have a clear purpose.
Use lights only when and where they
are needed.
Shield and aim your light so it only
falls downward and where it is
useful.
Lights should be no brighter than
necessary to save money and
reduce glare.
Lights should only be on when
needed. Use timers and motions
sensors.
Warm-colored light causes less
skyglow. Use amber-toned lights
whenever possible.
Is it useful?
Is it targeted?
Is it low-level?
Is it controlled?
Is it warm-colored?
Visit darksky.org to learn more
about the importance of the night
and what you can do to reduce
light pollution around your home
and community.
Learn more
Learn more about light pollution
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1441 Edgewood Dr
Palo Alto, CA 94301
April 26, 2025
Kelly Cha
Senior Planner
Planning and Development Services
250 Hamilton Avenue, Fifth Floor
Palo Alto, CA 94301
RE: Outdoor Lighting Update (“Dark Sky”)
Dear Ms. Cha:
I shared in my prior letters to you and city staff (“Staff”), the Planning & Transportation Committee (“PTC”), and the City Council for the City of Palo Alto (“City Council”) my opposition to the proposed lighting ordinance currently under consideration. I watched with great sadness the City Council on April 7, 2025 pass a motion to incorporate even more egregious conditions into the poorly drafted outdoor lighting ordinance, particularly the expansion to cover any existing light after 10 years.
As Staff prepares a new draft ordinance responsive to the City Council’s motion, I ask Staff to consider the following:
Deep security concerns. Residents of Edgewood Dr have a valid and deep concern about safety and security given the frequent and repeated crime we and our property face, the growing unhoused population living immediately adjacent in the San Francisquito Creek (“Creek”) combined with the City’s unwillingness or inability to address the growing issue, and our immediate proximity to East Palo and the spillover impact of frequent crime. The most obvious remedy is to exempt houses on this street from the ordinance or significant portions of the ordinance. While I appreciate Staff’s concern with defining a “high crime” neighborhood, it is vital that the City Council’s direction to address those with “special security concerns” provides adequate relief for homeowners abutting the Creek to install and operate sufficient lighting to protect ourselves. I am terrified of the safety issues my wife and young daughter will face returning to a dark house, trying to take out the trash through a dark backyard, as they are forced to navigate an unlit pool, or are unable to see criminals accessing our yard. Through expensive renovations we can mitigate some of the safety issues caused by this poor ordinance, some of the most severe will remain. Fear for our safety and security is heightened when combined with the other ordinances also under consideration – imagine being forced to no longer allowed have adequate outdoor lighting, no longer allowed to maintain a fence separating you from criminals and unhoused population, and then having to cover your windows in dots so you cannot even see the criminals concealed in the darkness with unfettered access to your backyard. These ordinances, individually and collectively, greatly compromise our safety and security. Please understand these fears are very real for us; we have even started to look at buying firearms and obtaining conceal and carry permits just so we can come home at night!
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Cost to comply exception / legal challenges and taking claim. With the expansion to cover all existing fixtures, the City must add an exception for properties that would incur excess cost to comply. After years of planning and building, I recently completed construction of my brand new home which I previously expected to be our family’s “forever” home. The preliminary estimate to comply with the new draft code as written requires that I destroy approximately $90,000 of lighting (and fan) materials and spend approximately $210,000 in new materials and labor. (This is just for the fixtures and related costs. The systems upgrades described later add further to this loss.) In 10 years, this would represent approximately $350,000 or more of expense (based on forecasted inflation rates). I can only imagine how much worse that will get with most of these fixtures and luminaires manufactured overseas. Imposing such extraordinary costs on homeowners is patently unfair. Would you want to have to work for 1-2 years just to comply with a new ordinance passed by the city? While my costs may be greater than some others, the cost to completely replace exterior lights for homeowners across Palo Alto is likely to be extremely high and grossly underestimated by City Council. Do we really want to pass this cost to so many homeowners? Do we really want to produce this much waste? A hardship exemption for only a temporary period of time, or requiring proof of financial distress, is wholly insufficient to remedy this loss. A cost to comply exemption is needed. Absent such an exception, it is paramount Staff and the City Attorney advise the City Council that passing such an ordinance leaves the city liable for a takings claim. While it is not my preference, please understand that passing an ordinance with a present value cost to me of $210,000 leaves me with no recourse but to challenge of the ordinance’s validity in court and assert a takings claim against the City for the entirety of this loss.
Shielding standard for non-confirming lighting after 10 years. The overwhelming majority of the costs noted above arise from the shielding requirement applied to non-conforming lights after 10 years.
One of the primary stated objectives of the ordinance is to reduce light pollution and minimize visual impact to neighbors. If the 10 year restriction is included in the next draft ordinance, I strongly recommend and beg to allow non-shielded lights so long as their lux output (as measured at the property border) satisfies the light trespass requirements (previously 0.5 lux but now proposed to be 0.1 lux). Like many homeowners, this would mean I would not be required to replace every fixture and could instead replace the luminaire and/or use dimming to bring existing fixtures into compliance. While this would not completely solve glare, this would meet the primary objectives of the ordinance with far reduced cost to homeowners. Moreover, this would further benefit the community since many fixtures would then have the “technical capacity” to comply under the 2 year window rather than waiting the full 10 years.
Lighting output measurement lumens vs lux. Most of the restrictions in the proposed ordinance 18.40.250 are written with regard to “lumens” of output. The original draft ordinance applied to new construction or new luminaires. As such, “lumens” was chosen presumably to make it easier for buyers to select luminaires with said rated lumens output (and for Staff to validate those specs during Planning). Now that the code will extend to existing luminaires, it is vital the code also express the limits in lux. It is my understanding that measuring lumen must be performed in a laboratory. I am told it is not practical to measure lumen output of an existing luminaire in the field. The could would therefore set a standard that could not be objectively measured by code enforcement either. Moreover, lumen is often the theoretical maximum which Item 8
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is reduced by the quality of the actual luminaire, the power system, distance, and other factors.
One important benefit of expressing output in lux is that it will also allow lighting designers to construct systems with dimmed lights. Most lighting systems are better served running well below 100% of maximum output to extend the lifetime of transformers and luminaires, therefore reducing cost and waste. Most importantly, it will fixtures with luminaires that cannot comply by lumen to comply through dimming. For example, I have two outdoor fan with a down light, adjustable color that can be made to work at 2700K or less, but with lumen that is too high. The manufacturer does not make a down light that meets the lumen requirements. The light, however, is dimmable and could remain if a lux threshold were established.
Conflict in 18.40.250(f)(1)(B) with 18.40.250(e)(1). The draft ordinance 18.40.250(f)(1)(B) states that “No more than 420 lumens shall be allowed for permitted non-shielded outdoor lighting.” The drafting suggests the intent of this section is to allow non-shielded low voltage outdoor lights so long as the luminaire is less than or equal to 420 lumens. Section 18.250(f)(1) also states that low density outdoor residential lights are subject both to that constraint and all others. Section 18.40.250(e)(1)(B) states that all lights must be fully shielded unless it is low voltage up-lights with no more than 150 lumen. This presents a conflict that must be resolved. In the context of this ordinance, the 420 lumens output is most appropriate limit.
Exemptions for front porch. The draft ordinance 18.40.250(d) provides a list of exemptions, including for illuminated street numbers. This exemption presumably recognizes the legitimate public safety need for first responders to locate a property in the event of an emergency. I would contend that providing safety lighting at a property’s front door is a similar legitimate public safety need. Lighting at a home’s primary ingress and egress is of importance to guests, first responders, and others. For most properties, it is impractical to install motion sensors on a front porch. Given this ordinance is being applied to an urban center, lighting the front porch should be exempted, at least with regard to curfew.
Outdoor security light output. The outdoor security lighting output proposed in
18.40.250(f)(2)(D) is limited to 1,600 lumens. First, this is grossly inadequate for security light output over large areas. The result would force homeowners to install multiple security lights, which is both expensive and likely to be worse for light pollution (not to mention potentially more false positives). Instead, this section for outdoor security lights should be limited only to lux light trespass only as already provided in 18.40.250(f)(2)(C). Therefore, sub-paragraph (D) should be removed. It is worth nothing this change would greatly aid Edgewood residents with a legitimate safety need.
Outdoor security light programmability. The draft code 18.40.250(f)(2)(A) requires outdoor lights to be “fully programmable.” It is entirely unclear from the code, common knowledge, or from consulting experts as to what “fully programmable” means with respect to an outdoor security light. This statement should be removed.
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Outdoor kitchen lighting. The draft code 18.40.250(e)(3)(A) requires all outdoor lights to be 2,700K or less. Lighting professionals routinely recommend 3,000K for kitchens for safety. As with others, my brand new construction followed the lighting professionals’ recommendation and installed 3,000K luminaires in down lights at the outdoor kitchen (with all other outdoor lights of 2,700K). To promote safety, and in consideration that these are not decorative lights but instead task lights for preparing food, it would be reasonable to allow 3,000K luminaires in such down lights when they illuminate an outdoor kitchen.
Control light sensor. The draft code 18.40.250(e)(4)(C) requires lighting control systems to have a light sensor. As noted elsewhere, I recently built a new home. The residence includes a whole-house lighting control system from a well-known manufacturer. The professional lighting designers hired for the project all systematically recommended against a light sensor on the roof for the whole house system given their poor sensitivity and likelihood of failure. They instead all universally recommended time-based automation. In fact, the most common light sensor from the manufacturer used was discontinued years ago because they are so infrequently installed in today’s lighting control systems. The draft code already provides for time-based extinguishing of lights. Therefore, the only practical purpose of this provision is with regard to when lights are allowed to turn on. I therefore recommend adding a time-based alternative to a light sensor.
Again, as a practical example, it will cost me approximately $25,000 to add a light sensor to the lighting control system (if I am unable to find the discontinued part, otherwise the cost will likely be over $1m to replace the entire lighting system), whereas it is a simple program change to set the lights to not come on until after a specific time of morning.
As noted at the start, I strongly oppose the current ordinance requested by the City Council. I am even more concerned about the cumulative impact of these ordinances: lighting update, bird design standard, and stream protection. Taken together, they effectively condemn my new home as unlivable while incurring massive costs.
The foregoing analysis offers several areas where this specific proposed lighting code update could be made substantially less burdensome without materially impacting the stated objectives.
Sincerely,
Tom Fountain
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1441 Edgewood Dr
Palo Alto, CA 94301
May 4, 2025
Kelly Cha
Senior Planner
Planning and Development Services
250 Hamilton Avenue, Fifth Floor
Palo Alto, CA 94301
RE: Outdoor Lighting Update (“Dark Sky”)
Dear Ms. Cha:
I am writing as a follow-up to my letter of April 26, 2025 regarding the City of Palo Alto’s (the “City”) proposed lighting update. As shared previously, I strongly oppose the proposed ordinance and was deeply disturbed by the direction of the City Council on April 7, 2025.
I spent my weekend attempting to apply the proposed ordinance to each of the outdoor luminaires and lamps on my property. As Staff prepares a new draft ordinance responsive to the City Council’s motion, I ask Staff to consider the following recommendations in addition to those shared previously:
Measuring light output and promoting hex filters. The draft ordinance currently expresses lamp output limits in lumen. As noted in my prior letter, once extended to existing lamps, it is vital to instead measure the foot-candles (or lux) at the property border or express these limits as the maximum measured output in foot-candles at a specific distance. I also noted previously the importance of allowing field measurements to encourage dimming. This would significantly reduce the cost to property owners since existing lamping is often dimmable.
With or without either of these improvements to the draft code, please also consider allowing lighting designers to account for hexagonal cell louver filters (sometimes called “honeycomb” filters). Such filters significantly reduce glare and typically reduced effective light output by 20- 25% even though, by definition, the lamp’s lumen output is unchanged. Limiting output to a measured foot-candle value would account for filters without further change. If limits remain only in the lamp’s manufacturer-specified lumen, consider instead limiting output to the product of the lamp’s lumen times the effective light output if filtered. Alternatively, the lumen could be expressed both with and without a filter. For example, the low-voltage lighting might be limited to 150 lumen without a filter and 200 lumen when a hexagonal cell louver filter is installed. As a result, some property owners could install filters in existing luminaires and lamps rather than having to replace the entire luminaire and/or lamp. Taking hex filters into account would reduce the cost to comply with this proposed ordinance while simultaneously reducing glare and better achieving the stated objectives of the ordinance.
Clarify low-voltage shield exception in 18.40.250(e)(1)(B)(i). The draft ordinance section
18.40.250(e)(1)(B)(i) is intended to provide an exception for unshielded low-voltage lighting.
The current draft states this exception applies only to “low voltage landscape uplighting” (underlined for emphasis). Limiting this exception to only “uplighting” is confusing and Item 8
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unnecessary. Presumably “uplighting” means anything that is not “Fully Shielded” but that is ambiguous from the context. Moreover, lighting designers should be encouraged, not discouraged, from using low voltage downlights even if they fail to fully satisfy the “Fully Shielded” definition. Consider as an example the FX Luminaire LED Wall Light (hƩps://www.fxl.com/product/wall-and-step-lights/designer/mo). Only one faceplate, the one identified as WW, qualifies as “Fully Shielded,” none would be easily identifiable as “uplighting,” yet all should be in the scope intended by the low-voltage shield exception.
Striking the word “uplighting” resolves this drafting issue.
Correct fully shielded security lighting in 18.40.250(f)(2)(B). The draft ordinance
18.40.250(f)(2) is intended to allow outdoor security lighting that meets certain standards.
Section 18.40.250(f)(2)(B) establishes a height standard. The statement also requires that luminaire be “fully shielded”. Based on the definition of “Fully Shielded” provided in this draft ordinance, effectively no security light could comply. Compliance would require the light be installed such that lamps point straight down. Any projection “forward” of the luminaire would result in the lamp breaking the required plane extending from the bottom of said lamp. The requirement that these lights be “fully shielded” should be removed from this ordinance. If the intent of this phrase is to encourage security lights be aimed in a downward direction, then it should say so rather than reference “fully shielded” which has a specific definition.
Address security perimeter lighting in 18.40.250(f)(2)(C). City Council directed Staff to replace all references to 0.5 foot-candle of spillover with 0.1 foot-candle of spillover. This change, even if applied elsewhere, should not be applied to this section. A limitation of 0.1 foot- candle effectively eliminates the use of security lighting near a fence. Even if aimed down, reflected light off other surfaces will exceed this threshold. It is untenable to have security lighting so limited where it is needed to illuminate an area near a fence.
Correct typo shielding exception in 18.40.250(e)(1)(iii). Section 18.40.250(e)(1)(iii) provides an exemption for string lights and erroneously refers to 18.40.250(f)(5). It should instead refer to
18.40.250(f)(6).
Thank you for your continued work to craft an ordinance that does not create such negative impact to city residents.
Sincerely,
Tom Fountain
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City Council
Staff Report
From: City Manager
Report Type: INFORMATION REPORTS
Lead Department: City Manager
Meeting Date: November 10, 2025
Report #:2509-5175
TITLE
Independent Police Auditor's (IPA) Report of Review of Investigations Between December 2024 and May 2025 and Police Department Use of Force Report for the Same Period
BACKGROUND AND ANALYSIS
Since 2006, Palo Alto has utilized an Independent Police Auditor (IPA) to conduct secondary review of certain investigations of uniformed Police Department personnel and provide related services. Since the inception of the independent police auditing program, the City has contracted with the Office of Independent Review (OIR Group), to provide these services. The following report transmits the Independent Police Auditor (IPA) Report on Investigations Completed as of May 31, 2025. For reference, the prior IPA report was published April 21, 2025 as an Informational Item1. The Police Department’s website lists all past Independent Police Auditor Reports, here2. Attachment A contains the current IPA report for investigations completed as of May 2025. Per Council direction, the Police Department also shares use of force information through a report provided alongside each IPA report, included here as Attachment B and covers the time period of December – May 2025. The Police Department’s responses to the IPA report recommendations are included here as Attachment C.
Consistent with standing practice, this report is issued as informational for the Council and the public. In light of heavy Council agendas through the end of the year and the straightforward contents of this report, staff has not scheduled a study session with OIR Group at this time.
Should Council members wish to schedule a study session in early 2026, please advise the City Manager.
1 Independent Police Auditor's (IPA) Report of Review of Investigations as of November 2024 and Police Department Use of Force Report for July - November 2024 https://cityofpaloalto.primegov.com/portal/item/?meetingItemId=85a7fb9e-a7ed-45eb-a6ae-2b02ade31e02 2 Palo Alto Police Department Accountability Webpage:
https://www.cityofpaloalto.org/Departments/Police/Accountability Independent Police Auditor Reports Webpage: https://www.cityofpaloalto.org/Departments/Police/Accountability/Independent-Police-Auditor Item A
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Process to File a Complaint to the IPA
The public can find more information about filing a complaint through the link here:
www.cityofpaloalto.org/Departments/Police/Accountability/Employee-Complaint Complaints may also be directed to the Independent Police Auditor as follows:
Contact: Mike Gennaco
Phone: (323) 821-0586
Email: [email protected]
Or mail to: OIR Group 1443 E. Washington Blvd., #234 Pasadena, CA 91104
FISCAL/RESOURCE IMPACT
The OIR Group is already contracted with the City and this report did not incur any additional expenses.
ENVIRONMENTAL REVIEW
The City’s Independent Police Auditor activities are not a project under section 15378(b)(25) of the California Environmental Quality Act Guidelines (administrative activities that will not result in direct or indirect physical changes in the environment).
ATTACHMENTS
Attachment A: Independent Police Auditor's Report - Review of Investigations as of May 2025 Attachment B: Police Department Use of Force Report for December 2024 – May 31, 2025 Attachment C: Police Department Responses to IPA Report, October 2025 APPROVED BY:
Ed Shikada, City Manager
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1 INDEPENDENT POLICE AUDITORS’ REPORT
Review of Investigations Completed as of 5-31-25
Presented to the Honorable City Council
City of Palo Alto
2025
Prepared by: Michael Gennaco and Stephen Connolly
Independent Police Auditors for
the City of Palo Alto
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2 Introduction
This Report is one of the shortest in our tenure as the oversight entity of the Palo Alto Police Department (PAPD). On a twice-yearly basis, our responsibility is to review and write about cases completed by PAPD management across specifically delineated categories. That "workload" is accordingly driven by timing and by PAPD activity, both in the field and in the agency's own review processes.
This installment covers the first six months of 2025. It includes discussion of one misconduct allegation (initiated by the Department itself to address potential violations of its vehicle pursuit policy), one use of force (in which a less-lethal weapon was used to facilitate the detention of a suicidal woman with a knife), and three incidents involving "pointed firearms" (all of which were found to be justified and consistent with training).
We found ourselves in basis alignment with the Department's resolution of each of these matters. As in the past, we also offer related recommendations that are meant to enhance future operational effectiveness.
Variations in the number and complexity of cases during a specific period are familiar to us from our years in Palo Alto (as well as our work in other jurisdictions). Though this is one of the smaller groupings, the limited number of public complaints of misconduct (here zero) and criteria-matching force incidents is in fact consistent with PAPD's recent history.
And the tracking of pointed firearm events continues to become sharper as the process evolves with time.
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3 Internal Complaint Investigation
Case 1:
Factual Overview
PAPD received a report of a strong-arm robbery of a postal carrier that resulted in the taking of her cell phone. Several officers responded to a nearby city in response to tracking indications as to the phone's location. While in that city, the subject officer engaged in a pursuit of a vehicle that appeared to be fleeing from an officer affiliated with the neighboring jurisdiction.
That pursuit ended without apprehension of the suspect. But when the subject officer observed the same car upon returning to Palo Alto; it fled again and left behind a passenger whom the officer detained. The subject officer then attempted to join the subsequent pursuit when the driver sped away.
Eventually, the subject was successfully detained by other PAPD units.
PAPD Investigation
When reviewing the pursuit documentation, PAPD became concerned that the subject officer may have violated the Department’s vehicle pursuit policy. Accordingly, PAPD management self-initiated an investigation into those concerns. PAPD's subsequent assessment of the incident was thorough, and included an evaluation of vehicle speeds, body-worn and in-car video cameras, police reports, and statements from the subject officer.
The investigation revealed that during the second pursuit, the subject officer drove left of the concrete median with oncoming vehicles present on several occasions, drove through intersections against the light, and reached speeds of 91 miles per hour in a 45 miles per hour zone.
PAPD determined that the officer committed four sustained violations of the Department’s vehicle pursuit policy:
Initial Pursuit
1. Failure to notify the supervisor of the pursuit or its justification.
2. Failure to broadcast any information advising that he was in pursuit.
Second Pursuit
3. Joining the pursuit without supervisor authorization.
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4 4. Driving without regard for public safety.
IPA Review
IPA reviewed all of the investigative materials developed during PAPD’s investigation and concurred with the findings of PAPD. The investigation and subsequent analysis were rigorous.
Vehicle pursuits are among the most dangerous of law enforcement activities, creating a risk not only to participating officers and the subjects being pursued but also to uninvolved motorists and pedestrians. As a result, police agencies have established detailed policies that are intended to balance those risks against the interest in apprehending those that flee.
The evidence was clear in this case that the subject officer did not consider the limitations and requirements set out in policy when engaged in either pursuit. To PAPD’s credit, it also recognized the misconduct and appropriately found the officer in violation of Departmental expectations as set out by policy.
Use of Force Cases
Case 1: Use of Less Lethal Munition on Suicidal Person
Factual Overview
PAPD was called to a location in which others had observed a female with a knife apparently trying to hurt herself by using the knife on her lower arms and wrists. Officers arrived on scene and one officer took the role of crisis negotiator. The negotiating officer attempted to get her to drop the knife as other members of the response team were assigned roles of less lethal and lethal cover.
After several minutes of unsuccessful negotiation, the female began walking in the direction of the PAPD response team, still holding the knife. Responding PAPD personnel’s tactical deployment options were limited because the woman was on a narrow pathway. At that time, the negotiating officer yelled at the female to drop the knife and the less lethal operator yelled “Sage.”1 The less lethal operator then delivered one round that struck the female in the abdomen and caused her to go to the ground.
The response team then advanced on the female and was able to successfully dislodge the knife from her and take her into custody. She was handcuffed and admitted to the
1 The term “Sage” refers to the model of less lethal munition that was deployed; it fires a heavy rubber projectile.
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5 hospital for treatment of her self-inflicted wounds as well as the abdominal bruise caused by the less lethal munition.
At the hospital, the female said that her intent had been to end her life, and that she had hoped that the on-scene officers would kill her.
Supervisory Review of Force
PAPD’s robust supervisory review found that the use of the less lethal munition was consistent with the Department’s use of force policy. It noted that when the female began to advance on the officers still holding the knife, she presented a threat that justified the use of force.
To the Department’s credit, the secondary reviewer agreed with the assessment that a supervisor and officer who were on scene when the force occurred should have submitted supplemental reports to document their actions and observations of the incident. More significantly and creditably, PAPD’s leadership crafted an intervention whereby the two who did not write a supplemental report receive training on Department expectations of documentation when a serious force incident occurs.
IPA Review
IPA reviewed the police report, body worn camera footage, and the supervisory review and concurred that the use of force was consistent with PAPD’s use of force policy.
IPA also observed the multiple requests of the negotiator to drop the knife and to engage with the female. Once the female began to walk toward the arrest team, those commands became more forceful and the less lethal operator yelled “I’m going to Sage you.”2 Yet none of the commands directed at the female instructed her to stop her forward movement which was the concerning act that provoked the deployment of the less lethal munition. Ideally, instead of repeating the previously ignored instructions of “drop the knife” and yelling “Sage” (which was mostly for the benefit of the arrest team advising of imminent deployment), it would have been helpful for the command of “stop” to also have been directed to the woman.3
2 PAPD policy states that a “verbal warning of the intended use of the device should precede its application, unless it would otherwise endanger the safety of officers or is not practicable due to the circumstances.”
3 PAPD’s internal review concluded that there was technical compliance with the warning policy but noted that no member of the public would be reasonably expected to know what “I’m going to Sage you” means. It noted that subjects should have a chance to understand what a verbal warning is intending to convey, so that they can make a more informed decision if they want to comply with the commands of officers. To PAPD’s credit, the secondary reviewer directed that alternative warning options be developed and then presented to all sworn personnel at a future “Sage” training session. The reviewer noted that if officers were provided in advance with various Item A
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6 Moreover, the supervisory review found that two of the body-worn cameras assigned to supervisors did not function during the negotiations and use of force deployment.
Fortunately, other officers on scene did capture the incident. But it should be concerning that the two cameras assigned to supervisors did not properly function during the incident.
To its credit, PAPD’s internal review agreed and the second level supervisor crafted further instructions to supervisors on ways to ensure that the body worn cameras are timely examined in cases where footage is not captured.4 RECOMMENDATION One: PAPD should evaluate the warnings in any use of force incident to determine whether different warnings might have been effective.
RECOMMENDATION Two: PAPD should continue to emphasize to supervisors the need to timely review body-worn cameras when they do not operate as intended to ensure that the operators had undertaken proper testing and maintenance protocols.
"Pointed Firearm" Incidents
In keeping with a new protocol that is now in its third year, PAPD provided us with review packages for the completed managerial assessments of encounters that involved the pointing of a gun by one or more officers. There were three separate events within this audit period.
Below is a summary of the context for the deployments, along with the Department's supervisory assessment of each.
1. Officers conducted a high-risk traffic stop of a male who had violated a restraining order, and whom they knew to have a criminal history. The man eventually stopped but remained barricaded inside the vehicle and refused to surrender. A standoff ensued and
options to consider for verbal warnings, they may be more likely to give a warning that more understandably conveys to the subject what may be about to happen. The reviewer concluded that this, in turn, may increase the opportunity for subjects to comply with commands, and for officers to avoid having to use force. PAPD’s secondary reviewer should be commended for identifying the issue and developing a remedial plan designed to improve officer performance.
4 For example, personnel are instructed to “test” their body worn cameras at the beginning of any shift to ensure that they are functioning properly and properly charged. Supervisors reviewing any defective body worn camera deployment were instructed to timely check to see if the operator had undertaken such a test; the ability to do so expires within 60 days of the incident.
Moreover, we have been advised that PAPD is in the process of switching out its body-worn camera inventory due to the camera’s age and similar concerns with the performance of the cameras in recent months.
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7 lasted for nearly two hours before one of the officers successfully achieved the man's peaceful surrender. During the incident, two different officers who were providing lethal cover pointed their respective weapons at separate points in the process. The (second officer took over for the first, to allow that person to engage in negotiations with the subject.)
No issues were identified in the supervisory review; on the contrary, the reviewer found the officers' actions to be effectively controlled, and the actual weapon pointing was quite limited.5
2. Three PAPD officers responded to a call involving a possible commercial burglary in progress. Two subjects were eventually detained in the shrubbery surrounding the property. One surrendered without incident; the other, in a different location, tried to conceal himself. Two officers both pointed their firearms at the man while one gave commands. Then one re-holstered before moving in to handcuff the subject while the other provided cover.
The officers' actions were found to be consistent with training and expectations in terms of their weapon use. However, one of the three involved officers (including one of the weapon-pointers) was not wearing a body-worn camera).6 This issue was determined to be an inadvertent mistake related to the spontaneous need for response; it was addressed by the reviewing supervisor.
3. An officer located a vehicle that had been flagged by an alert system in connection with a recent home invasion robbery; after calling for backup and initiating a traffic stop, the officer was notified that the occupants were potentially armed and dangerous.
Accordingly, the officer exited the patrol car and pointed a firearm at the driver, who had pulled over without incident. The officer kept the weapon pointed until the arrival of a partner made it safe to approach; the officer was able to determine that the driver was cooperative and not holding a weapon, and accordingly re-holstered. The arrest proceeded without further incident.
The supervisor memo pointed out that the officer did not activate a body-worn camera until approximately the one-minute mark of the traffic stop. The officer's explanation revolved around the need to sync a new camera after a battery had died earlier in the
5 We noted that the officers were notably solicitous of the man after securing his cooperation, even offering him water after he had been handcuffed. This was in keeping with the professional demeanor – and language – that we noted in each of these incidents.
6 That officer's relevant actions were at least captured by another officer's recording.
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8 shift; the officer initially neglected to remove the camera from the in-car docking station but then remembered and put it on. This issue was addressed and memorialized.
IPA Review
We agreed with the determination that the officers' respective actions were valid in the context of the different enforcement actions involved. We also found that the review process was effectively robust. Supervisors did a meticulous assessment of camera recordings to identify key passages (which sometimes involved matching a different officer's camera to the actions of a pointing officer). And, interestingly, in at least one case the officers appeared to "err on the side of caution" by acknowledging their weapon points when video evidence was inconclusive as to their direction of aim while providing cover.
Expectations about rigorous documentation and thoughtful review seem to be becoming second nature in the agency, which is encouraging to see.
Meanwhile, we note a less favorable issue that has come to our attention before. In two of the three cases, at least one of the officers did not have a complete video record of his or her actions. Though the lapses were not overly detrimental in establishing what occurred (primarily due to the presence of other officers), and while both officers had understandable and mitigating explanations for the respective occurrences, we again urge PAPD to continue its emphasis on compliance with camera policy and expectations.
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DATE: OCTOBER 1, 2025
TO: HONORABLE CITY COUNCIL
FROM: POLICE CHIEF ANDREW BINDER
SUBJECT: USE OF FORCE SUPPLEMENT TO IPA REPORT
This memorandum responds to the City Council’s November 2020 direction to provide use of force summary data (which encompasses all use of force incidents in which a “Supervisor’s Report on Use of Force” has been completed by the Police Department) as an attachment to each Independent Police Auditor (IPA) report. Policy Manual §300 (“Use of Force”) requires that all uses of force by Police Department members “be documented promptly, completely, and accurately in an appropriate report.1” The policy also requires that, under certain circumstances, a “Supervisor’s Report on Use of Force” also be completed by the supervisor, and routed for approval through the chain of command up to and including the Police Chief. Most commonly, a “Supervisor’s Report on Use of Force” is completed after an officer uses some form of force that results in a visible or apparent physical injury to a subject or the subject complains of pain or alleges they were injured.
Consistent with the IPA’s expanded scope of administrative review established by the City Council in November 2020, the Department forwards the following types of use of force cases to the IPA for review and recommendations: all cases where a subject’s injuries necessitate any treatment beyond minor medical treatment in the field, and all cases where an officer uses a baton, chemical agent, TASER, less lethal projectile, canine, or firearm. The IPA’s scope of administrative review was further-expanded in July 2021 to include cases when a firearm is pointed at a subject.
Consistent with the practice established in the May 2023 iteration of this memorandum, the Department is choosing to release the race of the recipient(s) of any force used.
This summary covers the period of December 1, 2024 thru May 31, 2025.
Use of Force Cases
From December 1, 2024 thru May 31, 2025, the Police Department responded to more than 21,000 calls for service and effected more than 600 arrests. During that time, there were 7 cases where force requiring a “Supervisor’s Report on Use of Force” was used, and 2 of which fell within the IPA’s scope of administrative review. The IPA’s review of those 2 cases will appear in a future IPA report.
1 The Palo Alto Police Department Policy Manual is updated quarterly and posted online at https://www.cityofpaloalto.org/Departments/Police/Public -Information-Portal/Police-Policy-Manual.
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The current IPA report includes a review of 1 use of force incident, which occurred prior to December 1, 2024. In their review of this incident, the IPA concurred with the Department’s finding that the force used was justified by the circumstances and consistent with policy. The race of the subject upon whom force was used was White.
December 2024 thru May 2025 Use of Force Summary
Type of Force Number of Cases Status of IPA Review
Physical Strength 7 2 cases pending review; 5 outside of scope Chemical Agent 0
TASER 0
Baton 0
Less-Lethal Projectile 0
Canine 0
Firearm 0
Firearm Pointed at Person Cases
From December 1, 2024 thru May 31, 2025, officers pointed a firearm at a person on 9 occasions. Three of these cases appear in the current IPA report; the remaining 6 will appear in a future IPA report.
The current IPA report includes a review of 3 total incidents during which officers pointed a firearm at a person, each of which occurred between December 1, 2024 and May 31, 2025. In their review of these 3 incidents, the IPA concurred in each case with the Department’s finding that the pointing of the firearm was justified by the circumstances and consistent with policy. In the 3 incidents described in the current IPA report, the race of the subjects at whom a firearm was pointed was Hispanic (2), and Other (1).
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DATE: OCTOBER 1, 2025
TO: HONORABLE CITY COUNCIL
FROM: POLICE CHIEF ANDREW BINDER
SUBJECT: RESPONSE TO IPA RECOMMENDATIONS IN REPORT COVERING INVESTIGATIONS AS OF MAY 31, 2025
RECOMMENDATION #1: PAPD should evaluate the warnings in any use of force incident to determine whether different warnings might have been effective.
The Department agrees and, consistent with existing policy, will continue to evaluate the effectiveness of warnings in use of force incidents.
RECOMMENDATION #2: PAPD should continue to emphasize to supervisors the need to timely review body-worn cameras when they do not operate as intended to ensure that the operators had undertaken proper testing and maintenance protocols.
The Department agrees and, as part of its continued emphasis on this issue, the Department has implemented guidelines designed to expedite supervisor review of incident footage.
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City Council
Staff Report
From: City Manager
Report Type: CONSENT CALENDAR
Lead Department: Utilities
Meeting Date: November 10, 2025
Report #:2511-5402
TITLE
Adopt a Resolution Deferring CPAU Late Fees and Collection Actions for Certain Customers Affected by the Ongoing Federal Government Shutdown; CEQA Status – Not a Project.
RECOMMENDATION
Staff recommends Council adopt a Resolution that temporarily defers late fees and other collection actions for certain residential customers (Rate Assistance Program (RAP) participants and federal employees) who are anticipated to be in financial hardship due to the federal government shutdown.
EXECUTIVE SUMMARY
The current federal government shutdown has disrupted the income and benefits of many federal employees and low-income households nationwide. While exact figures of affected residents in Palo Alto are unavailable, we recognize the potential impact on our community and have proactively identified flexible utility billing measures such as partial payment or postponement of utility bill payments, term repayment arrangements, suspension of late fees, and expedited access to CPAU financial assistance programs that will support our affected RAP residential customers and federal employees during the current shutdown.
BACKGROUND
As of this writing, the federal government financial closure is now the longest continuous federal government lockdown in history. Federal government employees who have been furloughed or dismissed, essential workers who are legally required to work without paychecks, and rate assistance customers who may be impacted due to suspension of other federal benefits programs are facing the financial impacts beyond their control.
ANALYSIS
In order to help customers who are having difficulty paying their utility bills, CPAU currently administers bill repayment scheduling, as well as residential financial assistance on a routine basis through the RAP and ProjectPLEDGE, a community-funded utility bill grant program.
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However, due to the unique nature of the federal shutdown, staff believes that it would be helpful to create a special program that temporarily defers late charges and collection actions for customers who are likely to be impacted by the shutdown.
The attached Resolution would create a new, temporary deferral plan that would be available to (i) customers who are enrolled in the RAP and (ii) customers in households with a federal employee. The deferral plan would automatically apply to any RAP account. Federal employees would need to request inclusion.
For accounts on the plan, CPAU would not take any of the following actions with respect to utility charges incurred during the shutdown:
(i) apply late charges,
(ii) take collection actions such as referring an account to a collection agency or bringing civil action,
(iii) initiate termination or disconnection of services, (iv) lower the internal credit risk assessment for the accountholder or account, or (v) report non-payment to any external credit reporting agency.
These actions would be suspended during the shutdown and for one year following the end of the shutdown. If the utility charges incurred during the shutdown an account are still not fully paid by within a year of the end of the shutdown, CPAU would apply its usual late charges and collection efforts to the remaining balance. CPAU’s normal late charges and collection efforts would also apply to any service charges incurred after the end of the shutdown.
The resolution provides that CPAU may require installment payments during the year after the end of the shutdown for accounts that are on the plan. The Utility Administrator is authorized to create procedures and rules that implement the plan created by the resolution.
FISCAL/RESOURCE IMPACT
The financial impact to CPAU (primarily the loss of late fees), will be negligible. It is assumed that bill repayments will be completed as agreed. Any residential revenue losses requiring financial write-off are not projected to be significant.
The deferral of late fees and collection efforts is anticipated to l minimally affect cash flow; however, these are vital measures to support community welfare during this period. To the extent that funds are needed, the Utilities will utilize interest income as a non-rate revenue source.
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STAKEHOLDER ENGAGEMENT
These initiatives underscore the City's ongoing commitment to its residents and CPAU customers, ensuring that utility services remain accessible and affordable during federal disruptions. Further updates and assessments will be provided as the situation evolves.
ENVIRONMENTAL REVIEW
Council approval of financial relief options for some utilities customers impacted by the federal government shutdown is not a project under CEQA (Public Resource Code section 21065), as an administrative activity of government that will not result in any physical changes to the environment (14 CCR section 15378(b)(5)).
ATTACHMENT:
Attachment A: Resolution
APPROVED BY:
Alan Kurotori, Director of Utilities
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Resolution No.
Resolution of the Council of the City of Palo Alto Deferring CPAU Late Fees and Collection Actions for Certain Customers Affected by the Ongoing Federal Government Shutdown
R E C I T A L S
A. Since October 1, 2025 the Federal Government has been operating without funding appropriations.
B. Until appropriations are approved and go into effect, the Federal Government is “shutdown.”
C. During the shutdown many payments normally made by the Federal Government have been suspended; these suspended payments include wage payments to federal employees and payments to states that support certain food assistance and other programs.
D. It is not clear at this time how long the shutdown will persist.
E. Many Palo Alto residents are federal employees or are recipients of assistance that has been disrupted by the shutdown.
F. The City’s utility and public work enterprises provide vital services, including electricity, natural gas, water, sewer, stormwater, and refuse services, to the households of these residents.
G. As a result of the shutdown-related disruption to household cashflow, many of these households are anticipated to encounter temporary difficulty in paying their bills.
H. It is vital to the public health and safety that the City not disrupt public services to those most affected by the shutdown.
I. Pursuant to Chapter 12.20.010 of the Palo Alto Municipal Code, the Council of the City of Palo Alto may by resolution adopt rules and regulations governing utility services, fees and charges.
J. The City Council desires to defer certain consequences of non-payment of utility bills for residential customers that are most directly affected by the shutdown.
The Council of the City of Palo Alto RESOLVES as follows:
SECTION 1. During the Shutdown Period and the Recovery Period as it pertains to charges incurred during the Shutdown Period, the City will not, in connection with an Enrolled Account: (i) apply late charges, (ii) take collection actions such as referring an account to a Item AA1
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collection agency or bringing civil action, (iii) initiate termination or disconnection of services, (iv) lower the internal credit risk assessment for the accountholder or account, or (v) report non-payment to any external credit reporting agency.
SECTION 2. For any accountholder of an Enrolled Account, the Administrator may create a payment plan for the Enrolled Account that requires that the balance unpaid at the end of the Shutdown Period be paid in installments during the Recovery Period.
SECTION 3. The Administrator is authorized to promulgate procedures and rules for the administration of this Resolution consistent with the provisions of this Resolution. The Administrator may require that any request made by an accountholder pursuant to this Resolution be made in a manner or in a format required by the Administrator.
SECTION 4. For purposes of this Resolution, the following terms have the following meanings:
A. “Administrator” means: The Utilities Director or his designee.
B. “Enrolled Account” means: Any residential CPAU Account (other than a multifamily account that covers more than one dwelling unit) that either (i) is enrolled in the CPAU Rate Assistance Program or (ii) serves a Federal Employee Dwelling Unit, where the accountholder applies to the City for such treatment, and establishes that a dwelling unit served in connection with the account is a Federal Employee Dwelling Unit, in a manner to be designated by the Administrator.
C. “Federal Employee Dwelling Unit” means: A residential dwelling unit at least one of the occupants of which was employed by the United States Government on October 1, 2025.
D. “Shutdown Period” means: The period beginning on October 1, 2025 and ending on the day that an appropriations bill funding the federal government becomes law.
E. “Recovery Period” means: A 365-day period that begins on the day following the end of the Shutdown Period.
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SECTION 5. The Council’s adoption of this Resolution and the actions taken herein do not require review under the California Environmental Quality Act because they do not meet the definition of “project” set forth in Public Resources Code Section 21065 nor the CEQA Guidelines, 14 CCR section 15378(b)(5).
INTRODUCED AND PASSED:
AYES:
NOES:
ABSENT:
ABSTENTIONS:
ATTEST:
City Clerk Mayor
APPROVED AS TO FORM: APPROVED:
Assistant City Attorney City Manager
Director of Utilities
Director of Administrative Services
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