Item 8 Public Comment — Palo Alto City Council, November 10, 2025

From: Emily Renzel
To: Council, City
Subject: Please adopt strongest possible lighting ordinance Date: Monday, November 10, 2025 12:09:10 PM
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Dear Mayor and Members of the City Council:

Please adopt the recommendations of the Sierra Club and the Santa Clara Valley Bird Alliance for the strongest possible lighting ordinance. So few natural areas are left that we have to make our urban areas as safe and welcoming to birds and wildlife as we can. Lighting can be particularly disruptive to migrating birds, so please consider that as you adopt the lighting ordinance. Thank you.

Emily M. Renzel
Councilmember 1979-1991
From: Aiden Miao
To: Council, City
Subject: 11/10/25 Agenda Item 8: Please adopt a strong outdoor lighting ordinance Date: Monday, November 10, 2025 12:04:51 PM
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Dear Councilmembers,
I'm Aiden, a Junior at Palo Alto High School and a member of the Palo Alto Student Climate Coalition (PASCC). I've grown up in Palo Alto my whole life.

Please adopt a strong ordinance to protect birds, people, and our night sky. There is something special about seeing the stars that I believe all Palo Alto residents should have the privilege of experiencing.

Best,
Aiden Miao
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From: Phyllis Brown
To: Council, City
Subject: 11/10/25 Agenda item 8: please adopt a strong outdoor lighting ordinance.

Date: Monday, November 10, 2025 9:33:57 AM
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Mayor Lauing and members of the Council,
The "Dark Skies Initiative" on the website of the McDonald Observatory, University of Texas at Austin, lists six negative effects of light pollution: costs, energy consumption, health, safety, the invironment, and loss of nighttime sky. The website also lists four night-sky friendly lighting practices.

I urge the Council to adopt "an Ordinance Updating Palo Alto Municipal Code (PAMC) Section 18.40.250 (Lighting) of Chapter 18.40 (General Standards and Exceptions) and Amending Chapters 18.10, 18.12, 18.28, and Section 18.40.230 of Title 18 (Zoning) to Adopt New Outdoor Lighting Regulations."
All living beings deserve to live without unnecessary and damaging artificial light pollution.

Phyllis Brown
From: Kat Snyder
To: Council, City
Subject: Dark Sky Ordinance
Date: Monday, November 10, 2025 9:23:01 AM
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Dear Council,
Thank you so much for taking up discussion on the Dark Sky Ordinance. Growing up in Palo Alto, I have very fond childhood memories of looking up at the stars and finding the constellations at night from my own backyard. I also have fond memories of going out camping at Sequoia National Park and being able to actually see the Milky Way! I will defer to you on any policy specifics, I just wanted to note that this is an important topic, not just to help the birds but also to create a sense of wonder among children growing up and looking at the stars.

Take care,
~Kat Snyder
Palo Alto Resident
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From: Kaitlyn Parkins
To: Council, City
Subject: 11/10/25 Agenda Item 8: Support for Adoption of an Ordinance Updating Palo Alto Municipal Code (PAMC) to Adopt New Outdoor Lighting Regulations
Date: Monday, November 10, 2025 9:10:56 AM
Attachments: ABC Lighting Ordinance Support.pdf
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November 7, 2025
Re: 11/10/25 Agenda Item 8: Support for Adoption of an Ordinance Updating Palo Alto Municipal Code (PAMC) to Adopt New Outdoor Lighting Regulations
Dear Councilmembers,
I am Kaitlyn Parkins, M.S., Coordinator of the Glass Collisions Program for American Bird Conservancy (ABC) and I have studied and advocated for the prevention of bird-window collisions for over ten years. ABC is dedicated to conserving wild birds and their habitats throughout the Americas.

On behalf of ABC, we thank the City of Palo Alto for its leadership in updating the Outdoor Lighting (Dark Sky) Ordinance. This effort is an important step toward protecting local ecosystems, migratory birds, and human health from the growing impacts of artificial light at night. We urge Council to adopt the ordinance with several key improvements, which will help the ordinance better achieve its intent in reducing unnecessary light at night while maintaining functionality and safety for people.

Amend Section 18.40.250(c)(3) to remove the phrase “If a building permit is required” to apply the ordinance to all new installation, replacement, or modification of outdoor luminaires,
Remove all retrofit requirements for existing outdoor lighting and apply standards only to new or replacement fixtures (see Request #1), and
Shorten the compliance period for easily adjustable existing lighting fixtures to one year.

Excessive and poorly designed lighting is a serious hazard for birds. Light pollution disrupts migration, disorients nocturnal species, and fragments habitat. The Bay Area lies along the Pacific Flyway, where millions of birds depend on dark skies to navigate safely. Beyond birds, artificial light at night affects virtually every group of organisms, including insects, amphibians, mammals, plants, and humans, by disrupting natural rhythms, feeding and breeding behavior, pollination, and sleep cycles. Palo Alto’s leadership can make a real difference in reducing preventable bird mortality and improving ecological and human health across the region.

We also want to address concerns that lower color temperatures, reduced brightness, curfews, and This message needs your attention
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November 7, 2025
Re: 11/10/25 Agenda Item 8: Support for Adop�on of an Ordinance Upda�ng Palo Alto Municipal Code (PAMC) to Adopt New Outdoor Ligh�ng Regula�ons

Dear Councilmembers,
I am Kaitlyn Parkins, M.S., Coordinator of the Glass Collisions Program for American Bird Conservancy (ABC) and I have studied and advocated for the preven�on of bird-window collisions for over ten years.

ABC is dedicated to conserving wild birds and their habitats throughout the Americas.

On behalf of ABC, we thank the City of Palo Alto for its leadership in upda�ng the Outdoor Ligh�ng (Dark Sky) Ordinance. This eﬀort is an important step toward protec�ng local ecosystems, migratory birds, and human health from the growing impacts of ar�ﬁcial light at night. We urge Council to adopt the ordinance with several key improvements, which will help the ordinance beter achieve its intent in reducing unnecessary light at night while maintaining func�onality and safety for people. • Amend Sec�on 18.40.250(c)(3) to remove the phrase “If a building permit is required” to apply the ordinance to all new installa�on, replacement, or modiﬁca�on of outdoor luminaires, • Remove all retroﬁt requirements for exis�ng outdoor ligh�ng and apply standards only to new or replacement ﬁxtures (see Request #1), and
• Shorten the compliance period for easily adjustable exis�ng ligh�ng ﬁxtures to one year.

Excessive and poorly designed ligh�ng is a serious hazard for birds. Light pollu�on disrupts migra�on, disorients nocturnal species, and fragments habitat. The Bay Area lies along the Paciﬁc Flyway , where millions of birds depend on dark skies to navigate safely . Beyond birds, ar�ﬁcial light at night aﬀects virtually every group of organisms, including insects, amphibians, mammals, plants, and humans, by disrup�ng natural rhythms, feeding and breeding behavior, pollina�on, and sleep cycles. Palo Alto’s leadership can make a real diﬀerence in reducing preventable bird mortality and improving ecological and human health across the region.

We also want to address concerns that lower color temperatures, reduced brightness, curfews, and mo�on sensors could compromise community safety . Responsible ligh�ng— warm, shielded, and appropriately dimmed—improves visibility by reducing glare and preserving contrast. Mo�on sensors further support safety by providing light only when and where it is needed, drawing aten�on to ac�vity while preserving darkness at other �mes. Communi�es across the country have successfully implemented similar standards. Research and experience demonstrate that safety and environmental stewardship are not mutually exclusive.

By adop�ng this ordinance, Palo Alto can take a meaningful step toward protec�ng both people and wildlife. The updated standards will reduce preventable bird mortality , conserve energy , and create a safer, healthier nigh�me environment for residents and the many species that share the landscape. Palo

Alto’s leadership on this issue will set an important example for other ci�es working to balance safety, sustainability , and stewardship of the natural world.

Sincerely,

Kaitlyn L. Parkins, M.S.

Glass Collisions Program Coordinator
American Bird Conservancy

motion sensors could compromise community safety. Responsible lighting— warm, shielded, and appropriately dimmed—improves visibility by reducing glare and preserving contrast. Motion sensors further support safety by providing light only when and where it is needed, drawing attention to activity while preserving darkness at other times. Communities across the country have successfully implemented similar standards. Research and experience demonstrate that safety and environmental stewardship are not mutually exclusive.

By adopting this ordinance, Palo Alto can take a meaningful step toward protecting both people and wildlife. The updated standards will reduce preventable bird mortality, conserve energy, and create a safer, healthier nighttime environment for residents and the many species that share the landscape. Palo Alto’s leadership on this issue will set an important example for other cities working to balance safety, sustainability, and stewardship of the natural world.

Please find a PDF of our comments attached.

Sincerely,
Kaitlyn Parkins
Glass Collisions Program Coordinator
American Bird Conservancy
[email protected]
US Mountain Time Zone

From: herb
To: Council, City; Clerk, City
Subject: November 10, 2025 City Council Meeting, Item # 8: Outdoor Lighting Regulations Date: Sunday, November 9, 2025 5:35:38 PM
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NOVEMBER 10, 2025 CITY COUNCIL MEETING
AGENDA ITEM #8: OUTDOOR LIGHTING REGULATIONS
Unshielded LED Street Lights appear to be the main cause of light pollution that I notice in the areas of the city that I walk in when in appears to be daytime instead of night when there is no light from either the sun or the moon, but the City's LED Street Lights are not covered by this proposed Ordinance.

Staff first implemented the conversion of High Pressure Sodium street lights to LED street lights as a pilot project, and then obtained City Council approval to install the LED street lights in phases. (See https://www.cityofpaloalto.org/files/assets/public/v/1/library/news/led- streetlight-conversion-project-map.pdf.

At first it appears that staff did the conversion, but the most recent areas of the City were converted by contract. (See staff report #4116 at https://www.cityofpaloalto.org/files/assets/public/v/1/agendas- minutes-reports/reports/city-manager-reports-cmrs/year- archive/2013/final-staff-report-id-4116_led-street-lights-supply-and- installation.pdf.)
The Bid Summary Sheet at page 5 of that staff report indicates that only 100 house-side shields and 100 cul-de-sac-side shields were to be removed as part of that contract, which implies that for the most part shields remained, but I haven't had the opportunity to walk at night through the areas of the city covered by the contract.

When I walk at night on the 1100 block of Waverley Street between Lincoln Avenue and Kingsley Avenue, the street lights on one side of the street light up the sidewalk on the other side of the street.

Tonight Sunday, November 9, there will be a period of time between Astronomical Twilight (about 6:30 pm) when there is no light from the sun, and Moonrise (about 9:30 pm) when there is no light from the moon.

If you have an opportunity to walk on the 1100 block of Waverley at that time, check to see if the sky is dark and you can see the stars, and walk on the side of the street opposite the side with the LED Street Lights to see if the sidewalk is dark or light.

You need to know the Color Temperature of those LED Street Lights that might be different for different manufacturers.

Thank you for your consideration of these comments.

Herb Borock
From: Tom Fountain
To: Council, City; Lauing, Ed; Cha, Kelly
Subject: Proposed Outdoor Lighting Ordinance
Date: Sunday, November 9, 2025 12:24:40 PM
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Dear Honorable Mayor and Members of the City Council,
With respect to the proposed lighting ordinance, I am writing to support the Edgewood Neighborhood Alliance’s position on the following:

I support the exemption of homes on the creek-side of Edgewood Drive given their unique circumstances, including encampments in the creek, crime and quality of life issues, and access from East Palo Alto which lacks barriers to creek entry. There is a well-documented threat to health and safety of residents that demands this reasonable exemption.

The exemption for Edgewood properties contains an error and should be corrected to the following:
“(7) Single family residential sites adjacent to San Francisquito Creek and fronting on Edgewood Drive if the portion of the site subject to a permanent easement in favor of the Santa Clara Valley Water District (or its successor in interest) for flood control purposes is reconfigured after January 1, 2002. These sites shall be subject to the requirements under Section 18.40.250(e)(4)(A).” More generally, I oppose the proposed ordinance. I hereby incorporate by reference my prior objections expressed in writing to the City Council, the Planning & Transportation Commission (PTC), and city staff.

This ordinance fails to adequately establish the relationship between the new regulation and the proven benefit. The proposed ordinance imposes an unreasonably high burden on existing residences. In many cases it requires homeowners to replace entire fixtures, not just bulbs. As but one example, the estimated cost to bring my property into compliance is $210,000 between new light fixtures and having to replace custom cuts of stone, siding, and other materials upon which these fixtures are mounted. The environmental waste produced by this poorly considered ordinance more than offsets the stated environmental benefits.

There are many problematic issues raised by this proposed ordinance. The City Council is misguided in stating this is “only” a future cost; every Palo Alto homeowner selling their This message needs your attention
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property must now disclose this future cost to potential buyers. The City’s inability (and stated intent not) to enforce this code only serves to further pit neighbors against one another in a community that is already too acrimonious; City Council should use guidelines and incentives rather than criminalize lighting. There are many other similar technical issues with the proposed code that I have raised on multiple occasions, particularly its applicability to already built residences; it is incredibly disheartening that after 6+ months, staff chose not address even a single issue raised. It leads me to conclude this is entirely performatory and not at all about actually improving the lives of Palo Alto residents.

I strongly urge City Council take a more measured and practical approach to advancing this environmental goal. First, these changes should only be applied to new residential construction and not retroactively applied to existing residences. If existing properties must be covered, then limits should be expressed in lux rather than lumen so that practical techniques such as dimming can allow existing fixtures to comply.

The current proposed ordinance fails to balance property owner cost with the claimed benefits, creates unreasonable expense for homeowners, causes environmental harm from the premature replacement of fixtures and related construction, and fails to apply even practical solutions such as dimming to lighting issues. As a resident of Palo Alto, I beg City Council to send the ordinance back to Staff to better address these issues.

Sincerely,
Tom Fountain
Palo Alto resident
From: Marie Evitt
To: Council, City
Subject: outdoor lighting ordinance
Date: Sunday, November 9, 2025 10:58:29 AM
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Dear Councilmembers,

I urge you to adopt a strong outdoor lighting ordinance to protect birds, people, and our night sky. I am a Mountain View resident and I hope to reduce light pollution throughout the peninsula and Bay Area.

Sincerely,
Marie Evitt
Mountain View
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From: Kristin Sato
To: Cha, Kelly; Council, City; Lauing, Ed
Cc: Tom Fountain
Subject: Proposed Outdoor Lighting Ordinance, Line Item #8 Date: Saturday, November 8, 2025 8:00:53 PM
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Palo Alto City Council, [email protected] Ed Lauing, [email protected]

Re: Proposed Outdoor Lighting Ordinance

Dear Honorable Mayor and Members of the City Council,

With respect to the proposed lighting ordinance, I am writing to support the Edgewood Neighborhood Alliance's position on the following:

I support the exemption of homes on the creek-side of Edgewood Drive given our unique circumstances, including encampments in the creek, crime and proximity to East Palo Alto, which have no barriers to enter the creek.

The exemption for Edgewood properties contains an error and should be corrected to the following:

“(7) Single family residential sites adjacent to San Francisquito Creek and fronting on Edgewood Drive if the portion of the site subject to a permanent easement in favor of the Santa Clara Valley Water District (or its successor in interest) for flood control purposes is reconfigured after January 1, 2002. These sites shall be subject to the requirements under Section 18.40.250(e)(4)(A).”

It should be noted though that I generally oppose the proposed ordinance as previously addressed in prior objections to the City Council, the Planning & Transportation Commission (PTC), and city staff.

This ordinance fails to adequately establish the relationship between the new regulation and the proven benefit. The proposed ordinance imposes an unreasonably high burden on existing residences -- I moved into my new build house 2 years ago and will now have to spend an inordinate amount of money to bring my residence into compliance. This proposed environmental waste is obscene when compared to the unsubstantiated stated This message needs your attention
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environmental benefits.

Further, there are many problematic issues raised by this proposed ordinance. The City Council is misguided in stating this is "only" a future cost; any homeowner selling their property will now need to disclose this future cost to potential buyers. The Edgewood Properties are already being targeted by real estate brokers recommending that we sell quickly because the City's proposed changes will more likely decrease our home values.

The City's inability (and stated intent) to not enforce this code only serves to pit neighbors against one another in a place that is already so acrimonious; City Council should use guidelines and incentives rather than criminalize lighting. There are many other similar small issues with this proposed code; it is incredibly disheartening that after 6+ months, staff did not address even a single issue raised. It appears that this is entirely performatory and not at all about actually improving the lives of Palo Alto residents.

I strongly urge the City Council to take a more measured and practical approach to advancing this environmental goal. First, these changes should only be applied to new construction and not retroactively applied to existing residences. If existing properties must be covered, then limits should be expressed in lux rather than lumen so that practical techniques such as dimming can allow existing fixtures to comply.

The current proposed ordinance fails to balance property owner costs with the so- called proposed benefits, creates unreasonable expense for homeowners, causes environmental harm from the premature replacement of lights and related construction, and fails to apply even practical solutions such as dimming to these issues. Seriously, where is the environmental impact studies that would show the cost benefit to impose such onerous rules on whole City? As a resident of Palo Alto, I ask the City Council to send the ordinance back to Staff to be rewritten.

Thank you.

Kristin Sato

From: Andrea Eckstein Gara
To: Council, City
Cc: Hilary Glann
Subject: Support for Stronger Dark Sky Ordinance from 350 SV Palo Alto Date: Saturday, November 8, 2025 5:54:47 PM
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Dear Councilmembers,
As advocates for the environment, our group enthusiastically supports the more robust dark sky ordinance under consideration. Motion sensors and controlled, time-activated lights will keep us safe, as well as supporting the nocturnal creatures in our community. Dark skies are an important part of their ecosystem, and should be protected in the same way that we protect other natural habitats, such as Bay Lands and our canopy. Nearly half of the species on earth are nocturnal. Dark skies cue important behaviors and help them to navigate, nest, mate, forage, and hide from predators.

Insects are particularly vulnerable to light pollution. This is just one modern stressor, and scientists have reported that we are experiencing an insect apocalypse with 75% of the
insect biomass disappearing in just 30 years. As insects are a critical component of many food webs, we know that there will be ripple effects for birds, fish, mammals and humans.

About 75% of our crop varieties depend on insect pollination. Reduced yields lead to cascade events that have real human health impacts.

Finally, a dark sky can be a form of natural beauty that is available to anyone, even those without easy access to gardens and parks. We know that exposure to natural beauty and awe has many physical and psychological benefits,
lowering anxiety, improving
concentration, and reducing inflammation and heart rate.

Thank you for continuing to focus on this important topic, and please take the steps needed to make this an ordinance that truly gives us back our night sky. 350 SV Palo Alto
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Andrea Eckstein Gara, Co-chair
Hilary Glann, Co-chair
From: Bruce England
To: Council, City
Cc: Bruce England
Subject: Comment on agenda item 8 at 11/10 City Council meeting Date: Saturday, November 8, 2025 2:58:03 PM
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Hello council members:

I would like to voice my support for an outdoor lighting ordinance you will consider at your meeting. Although I'm a Mountain View resident, our own city is working on this as well, and the issue is regional in many respects. We truly need these update rules throughout the South Bay Area, and beyond for that matter.

Also, please consider incorporating suggestions from the Bird Alliance and the Sierra Club in the ordinance.

During public comments on this, I request that you cede my time to Shani Kleinhaus.

Thanks for your attention,
Bruce England
328 Whisman Station Drive
Mountain View, CA 94043
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From: Cathy Brown
To: Council, City
Subject: 11/10/25 Agenda Item 8: Please adopt a strong outdoor lighting ordinance Date: Saturday, November 8, 2025 11:11:34 AM
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To whom it may concern,
Please consider adopting a strong lighting ordinance that helps reduce the amount of light pollution that is created in Palo Alto every night.

I have lived here for most of my sixty years and remember being able to see the stars and moon on evening walks. Rarely does that occur now. There are SO many lights everywhere, from solar powered ones that stay on all night, to extremely bright flood lights triggered by someone passing by a home, to bright car and street lights.

Lighting helps for safety but we must do it with more care. We are affecting the flights of birds and insects with unknown ripples throughout our ecosystem. Migratory patterns are shifted.

As well, every evening I must close doors within my home to block light from my neighbors' myriad of lights which shine all night to have semi-darkness within my bedroom.

We have lost the dark of night. Please consider adopting resolutions that will help restore this.

Thank you,
Cathy Brown
Boyce Avenue, Palo Alto
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From: Winter Dellenbach
To: Council, City
Subject: Needed - The locals need Dark Skies
Date: Saturday, November 8, 2025 11:04:58 AM
Dear Council Members - It is time our City, often a policy and issue leader, now joined other large and small cities in our state, country and abroad in adjusting needed lightening to a responsible, reasonable level.

You are on a Council that pays attention to local residents. It is on their behalf, as seen below, that I write this email (furry feet, nails, hooves and talons prevent them doing so themselves).

For the migrating birds, the fish and wildlife along our creeks, for the owls and hawks hunting in our parks and open space that keep vermin in check. And for our own species to see the night sky and to reap the many benefits darker skies foster.

An egregious example of over the top lighting is in Bol Park where a very big light is bolted high up in an old Oak tree shining on the path along Matadero Creek, shining way beyond the path onto big grassy areas.

There is no need for this. Path lighting needs to be changed so that is low, pointing down on the path and only as needed.

Science supports darker skies. Palo Alto should too.

Winter Dellenbach

From: Paul Lynam
To: Council, City
Subject: 11/10/25 Agenda Item 8: Please adopt a strong outdoor lighting ordinance Date: Saturday, November 8, 2025 2:44:51 AM
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Honorable Mayor and City Council,
Please find attached a pdf file comprising written public comment regarding "Adoption of an Ordinance Updating Palo Alto Municipal Code [...] for Protection of the Environment", scheduled to come before the Council on 10 November 2025.

The University of California Observatories/Lick Observatory (UCO/Lick) endorses the proposed Palo Alto Outdoor Lighting (Dark Sky) ordinance. Furthermore, the Council is encouraged to incorporate the recommendations compiled by expert environmental advocacy groups such as the SCV Bird Alliance.

Since light pollution/(A)LAN is a regional trespass, it is best addressed by regional coordination. The proposed ordinance demands ‘increasing efforts to raise awareness’. It is recommended that some of these efforts be directed towards coordinating with neighbouring local authorities with a view to ultimately developing a regional strategy to reduce the light pollution (A)LAN phenomenon.

Thank you for your attention and service to the community.

Yours faithfully,
Dr Paul D. Lynam FRAS
Astronomer
UCO/Lick Observatory
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University of California Observatories/Lick Observatory 7281, Mount Hamilton Road,

MOUNT HAMILTON,
CA 95140
8 November 2025
Honorable Mayor and City Council,
Item 8. Adoption of an Ordinance Updating Palo Alto Municipal Code (PAMC) Section

18.40.250 (Lighting) of Chapter 18.40 (General Standards and Exceptions) and Amending Chapters 18.10, 18.12, 18.28, and Section 18.40.230 of Title 18 (Zoning) to Adopt New Outdoor Lighting Regulations; CEQA Status — Exempt pursuant to CEQA Guidelines Section 15308 (Actions for Protection of the Environment) This communication comprises written public comment regarding the above-titled matter scheduled to come before the Council on 10 November 2025. The University of California Observatories/Lick Observtory (UCO/Lick) endorses the proposed Palo Alto Outdoor Lighting (Dark Sky) ordinance for the following reasons:
• Public opinion: Experience shows that invariably, the majority public opinion is in favour of measures to control light pollution 1. The needs of astronomical observatories are in accord and well-aligned with Council direction from 7 April 2025, and sentiment expressed by environmental advocates and many public participants in the process.
• Astronomy, Environment, Economy: Dark Skies benefit multiple aspects of the environment and economy (including, but not limited to, noturnal nature-based pursuits such as stargazing and astronomical research as well as agricultural pest control). • Public Health: Reduction in harms of (A)LAN to human health, circadian disruption, etc.

This correspondent has been an advocate for dark skies for 40+ years, informing local and regional authority lighting policies in Europe and North America. The writer holds a degree in astronomy with applied physics, masters in physics, doctorate in astrophysics and has worked at academic research insti- tutes and/or observatories in the UK, Germany, Chile and the US for 30+ years, joining the University of California Observatories/Lick Observatory (UCO/Lick) — the world’s first high altitude astronomical observatory — in 2011. Lick Observatory hosts over 10 telescopes, plus multiple cutting-edge research and technology development instruments, serving hundreds of faculty (including Nobel laureates) and students of the University of California system, in addition to 35,000 visitors annually. Named in classic literature2 and during the Apollo program 3, Lick Observatory leads the world, setting standards on astronomical matters and responsible lighting.
1Also referred to in academic literature as Anthropogenic Light At Night (ALAN) or simply Light At Night (LAN) 2H. G. Wells (1897)The War of the Worlds.
3NASA Apollo 11 (20 July 1969) CAPCOM to Tranquility Base: ‘The Lick Observatory in California reports a return on the laser experiment’.

A fundamental problem pervading California is that the night sky is not considered an environmental phenomenon under CEQA 4’. This, despite the United Nations declaration:

An unpolluted night sky that allows the enjoyment and contemplation of the firmament should be considered an inalienable right of humankind equivalent to all other environmental, social, and cultural rights.

By excluding the night sky from its description of ‘the environment’, CEQA is deficient. Hence, it becomes the responsibility of California’s local authorities to safeguard the protection of dark skies and public health.

The nature, physics, regional trespass and harms of light pollution/(A)LAN have been understood for decades. The scientific concencus (based on multitudinous, multi-disciplinary, independent, peer- reviewed studies) is indisputable: (A)LAN harms the mission of astronomical observatories; (A)LAN causes changes in the environment that have adverse direct or indirect effects on fauna and flora (e.g. bats, insects, trees) altering our sense of place; (A)LAN is a hazard to human health and probable carcinogen. Blue light (primarily from LEDs 5) is toxic for all life.

Harm to Dark Skies & Astronomical Pursuits
The prevalence of light pollution/(A)LAN across the industrialized world is accelerating at a rate out- pacing population growth. Over the past 25 years, growth rates of between 49% and 270% have been measured. For rapidly developing conurbations in the industrialized world (e.g. San Francisco Bay Area) this figure could be as high as 400%. Some estimates suggest growth rates of 7% to 10% annually (Kyba et al. 2023). Light pollution trespasses regionally: Metropolitan light impacts astronomical sites up to 200–300 km away (Duriscoe et al. 2018).

Regardless of the technology or originating fixture, any and all light sources which interact with the atmosphere contribute an additive effect to scattered light, elevating the intensity of the diffuse sky background. Every additional light source elevates the problem. Additional scattered light does not simply ‘blend in’ to the pre-existing level of diffuse sky background light.

Blue light — particularly (since circa 2013) blue-rich LEDs — contributes disproportionately to light pollution. LEDs combine emission from peaks of intensity across many colors — particularly blue — thus contaminating the entire visible spectrum, whereas incandescent or discharge (e.g. sodium) lighting consists of isolated spectral peaks, with adjacent spectral regions free from contamination. In particular, with few exceptions, practical electric lights prior to LEDs were wholly absent of a blue component . In contrast, LEDs produce a preponderance of blue light . In large part, sky-glow is a consequence of the physics of ever-present aerosols (e.g. water vapor, particles, etc.) which redirect, or scatter light — not exclusively direct illumination. Scattering is responsible for twilights, renders clear daytime skies as blue and cloudy skies as gray. One of the dominant scattering processes, Rayleigh scattering , has not simply an additive or multiplicative dependence, but a fourth-order power law dependence, such that bluer (shorter) wavelengths are much more strongly scattered than redder (longer) wavelengths . 4CEQA: The California Environmental Quality Act.
5LEDs: Light Emitting Diodes
2 DarkSky Recommendations
The proposed ordinance incorporates best practice guidelines recommended by DarkSky International 6 to minimize damage to dark skies, and address the pleas of researchers to reduce, curb, mitigate or reverse the proliferation of light pollution/(A)LAN:

To maintain our ability to carry out top-grade astronomical research, it is nec- essary that the [A]LAN affecting observatories is reduced as soon as possi- ble . . . [this] might be the last call for a serious, collective, unambiguous, no- compromise action to lower light pollution now .
— Falchi et al. (2023)
Harm to Public Health from Pervasive Light Pollution: ‘Edison’s Cancer Epidemic’.

Light pollution from artificial light is harmful to human health — considered by some ‘the biggest public health crisis going on right now7’. Every major disease is associated to some extent with short sleep/long light. Sleep disorders are now arguably the most prevalent health concern in the industrialized world (Bogard 2013, Winter 2017). The consensus that has emerged from over 10,000 peer- reviewed scientific articles published by over 30,000 scientists cements the conclusion that light at night is carcinogenic, as well as causing a host of other medical problems . Mammals are highly sensitive to light at night, which has the power to dramatically, negatively affect circadian rhythms. Circadian rhythms control aspects of physiology, behavior, metabolism, body temperature, blood pressure and pineal hormone (e.g. melatonin) secretion. It is the shorter wavelengths of light (i.e. blue) that most affect melatonin production. LEDs — with their preponderance of blue emission — are of most concern.

Beginning in 1970s, multitudinous studies have identified links between circadian disruption to behav- ioral changes , sleep disorders , (e.g. Wang et al. 2022), mental disorders , (mood and anxiety disorders e.g. Paksarian et al. 2020), diabetes, (e.g. Zheng et al. 2023), depression, obesity, coro- nary heart disease , (e.g. Muenzel et al. 2020, and references therein), Mild Cognitive Impairment, MCI (a transitional phase between normal aging and dementia e.g. Chen et al. 2022), dementia and Cerebrovascular disease (including stroke and other conditions affecting blood flow to the brain e.g.

Wu et al., 2024).

Circadian disruption, induced by light pollution, is harmful — considered a probable human carcino- gen by WHO 8 (Stevens et al. 2011, Bogard 2013). The US National Institutes of Health (NIH) concurs: review panels at the WHO and US NIH have confirmed the carcinogenic risk of electric light. The American Medical Association (AMA) and groups (e.g. The American Heart Association, heart.org/stroke.org; breatscancer.org; The Sleep Foundation) advocate for light pollution control efforts for public safety. Hundreds of scientific studies have shown the association between electric light exposure and cancer, and the biological mechanisms by which it occurs. Electric light has been called ‘the tobacco of breast and prostate cancer’ . These two cancers — along with 6DarkSky International (formerly, the International Dark-Sky Association). 7Clip: Prof. R. Fosbery: Interactions between light & life (21 October 2022) [02:16–02:24]. 8The World Health Organization.
3 cancers of the lung, colon and rectum have multiple, well-established causal pathways between those cancers and light pollution. Modern texts describe the prevalence of light at night as ‘ Edison’s Cancer Epidemic ’ (Moore-Ede 2024).

Over the past decade, ‘mitigation’ has gradually been expunged from the lexicon of students of (A)LAN and dark-sky advocates. Multi-disciplinary, independent, peer-reviewed scientific studies plead:

We advise people, especially those living in urban areas, to consider reducing exposure [to outdoor artificial light] to protect themselves.
— Jianbing Wang, Ph.D (25 March 2024) 9
Harm to Public Health from LEDs: ‘The New Asbestos’
We are now realizing that ‘blue light is toxic for all life 10’. Light at night originating from LEDs directly damages cellular mitochondria via ‘the same process produced by Chernobyl radiation [. . . ] a slow death 11’. Public health experts refer to the effect of growing light pollution as ‘21st century scurvy’ . LEDs are described as ‘the New Asbestos 12’.

We may regret [introducing LED and fluorescent light tubes] due to to health hazards as well as economic and social costs associated with it, and, therefore, it should be considered unsustainable .
— Haim & Portnov (2013)
Conclusion
The message is clear, the astronomical community, dark-sky advocates, environmentalists, public health researchers are pleading for:

Serious, collective, unambiguous, no-compromise action to lower light pollution now.
— Falchi et al. (2023)
Curb the surging light pollution at night.
— Chen et al. (2022)
Reduce artificial light at night.
—Al Nagger & Anil (2016)
9American Heart Association/heart.org/stroke.org
10Clip: Prof. R. Fosbery: Concerns on the impact of life from blue light LEDs (12 May 2022) [05:52–06:03]. 11Clip: Prof. R. Fosbery: Interactions between light & life (21 October 2022) [01:02:05–01:02:16]. 12Clip: Prof. R. Fosbery: Interactions between light & life (21 October 2022) [01:04:40–01:04:52]. 4 Regulations on nighttime advertising [. . . ] and switching off . — Haim & Portnov (2013)
The City of Palo Alto is not alone in considering and/or adopting new outdoor lighting regulations: In nearby communities such as West Marin and Santa Rosa, citizens have been proactive in demanding DarkSky-compliant lighting ordinances. Similar efforts are gaining traction at State level (witness the progression of legislation to reduce light pollution 13). The time is coming when light pollution will be as strictly regulated as noise or air pollution (Ecklof 2023).

Again, the University of California Observatories/Lick Observatory (UCO/Lick) endorses the proposed Palo Alto Outdoor Lighting (Dark Sky) ordinance. Furthermore, the Council is encouraged to incor- porate the recommendations compiled by expert environmental advocacy groups such as the SCV Bird Alliance.

Since light pollution/(A)LAN is a regional trespass, it is best addressed by regional coordination. The proposed ordinance demands ‘increasing efforts to raise awareness’. It is recommended that some of these efforts be directed towords coordinating with neighbouring local authorities with a view to ultimately developing a regional strategy to reduce the light pollution (A)LAN phenomenon.

Thank you for your attention and service to the community.

Yours faithfully,
Dr Paul D. Lynam FRAS
Astronomer
UCO/Lick Observatory
13Legislation to reduce light pollution progresses to Senate Committee on Appropriations (4 August 2023). 5 References
Al Nagger, A., Anil, S. (2016)
Artificial Light at Night and cancer: Global Study
Asian Pacific Journal of Cancer Prevention, 17 (10), 4661.

Bogard, P. (2013)
The End of Night: Searching for natural darkness in the age of artificial light Back Bay Books / Little, Brown and Company
ISBN 978-0-316-18290-4 (hc) / 978-0-316-18291-1 (pb).

Bauby, J-D. (1997)
The Diving Bell and the Butterfly
Vintage
ISBN 9780375701214.

Chen, Y., Tan, J., Liu, Y., Dong, G., D., Yang, B. Li, N., Wang, L., Chen, G., Li, S., Guo, Y. (2022) Long-term exposure to light at night and mild cognitive impairment; A nationwide study in Chinese veterans
Science of the Total Environment, 847, 157441.

Duriscoe, D., Anderson, S., Luginbuhl, C., Baugh, K. (2018) A simplified model of all-sky artificial sky glow derived from VIIRS Day/Night band data Journal of Quantitative Spectroscopy and Radiative Transfer, 214, 133.

Eklof, J (2023)
The Darkness Manifesto: On Light Pollution, Night Ecology and the Ancient Rhythms that Sustain Life
Scribner
ISBN-13 978-1668000892.

Falchi, F., Ramos, F., Bara, S., Sanhueza, P., Arancibia, M., Damke, G., Cinzano, P. (2023) Light pollution indicators for all the major astronomical observatories Monthly Notices of the Royal Astronomical Society 519, 26.

Garstang, R. (1989a)
Night-sky brightness at observatories and sites
Publications of the Astronomical Society of the Pacific, 101, 306.

Garstang, R. (1989b)
The status and prospects for ground-based observatory sites Annual Reviews of Astronomy and Astrophysics, 27, 19.

Gaston, K. J., Sanchez de Miguel, A (2022)
Environmental Impacts of Artificial Light at Night
Annual Review of Environment and Resources, 47, 373.
6 Green, R. F., Luginbuhl, C. B., Wainscoat, R. J. Duriscoe, D. (2022) The growing threat of light pollution to ground-based observatories The Astronomy and Astrophysics Review, 30, 1.

Haim, A., Portnov, B. (2013)
Light pollution as a New Risk Factor for Human Breast and Prostate Cancers Springer Dordtrecht ISBN 978-94-007-6219; Published 12 June 2013.

IARC (2020)
Night Shift Work
IARC Monogr. Identif Carcino Hazards Hum, 124: 1–371. https://www.iarc.who.int/news-events/iarc- monographs-volume-124-night-shift-work/
Kyba, C., Altintas, Y., Walker, C., Newhouse, M. (2023) Citizen scientists report global rapid reductions in the visibility of stars from 2011 to 2022 Science, 379, 265.

Miller, S., Cajochen, C., Green, A., Hanifin, J., Huss, A., Karipidis, K., Loughran, S., Oftedal, G., O’Hagan, J., Sliney, D., Croft, R., van Rongen, E., Cridland, N., d’Inzeo, G., Hirata, A, Marino, C., R¨ o¨ osli, M., Watanbe, S., and International Commission on Nin-Ionizing Radiation Protection (ICNIRP) (2024)
INCNIRP statement on short wavelength light exposure from indoor artificial sources and human health Health Physics 126(4), 241–248.

Moore-Ede, M. (2024)
The Light Doctor: Using light to boost health, improve sleep and live longer Circadian Books
ISBN 978-8-9906869-0-8 (pb).

M¨ unzel, T. Hahad, O., Daiber, A. (2021)
The dark side of nocturnal light pollution. Outdoor light at night increases risk of coronary heart disease European Heart Journal 2021 Feb 21; 42(8), 831–834 https://www.ncbi.nlm.nih.gov/pmc/articles/PMC7897459/ Paksarian, D., Rudolph, K., Stapp, E. (2020)
Association of Outdoor Artificial Light at Night With Mental Disorders and Sleep Patterns Among US Adolescents
JAMA Psychiatry 2020, 77(12), 1266–1275.

Stevens, R., Hansen, J., Costa, G. et al. (2011)
Considerations of Circadian Impact for Defining ‘Shift Work’ in Cancer Studies: IARC Working Group Report
Occupational Environmental Medicine 68, 154. https://pubmed.ncbi.nlm.nih.gov/20962033/ 7 Winter, C. (2017)
The Sleep Solution: Why Your Sleep is Broken and How to Fix it Berkley
ISBN-13 978-0399583605.

Wang, L., Gong, Y., Fang, Q. et al. (2022)
Association Between Exposure to Outdoor Artificial Light at Night and Sleep Disorders Among Children in China
JAMA Netw Open. 2022 May 2;5(5):e2213247
Wu, Y., Shen, P., Yang, Z., et al. (2024)
Outdoor Light at Night, Air Pollution, and Risk of Cerebrovascular Disease: A Cohort Study in China Stroke (American Heart Association Journals), Vol 55, No 4 (25 March 2024) Zheng, R., Xin, Z., Li, M., et al. (2023)
Outdoor light at night in relation to glucose homeostatis and diabetes in Chinese adults: a national and cross-sectional study of 98,658 participants from 162 study sites Diabetologia, 66, 336.
8 From: Orly Schube
To: Council, City
Subject: Support a Strong Dark Skies Ordinance to Support Our City Date: Friday, November 7, 2025 5:17:57 PM
CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.
i
Dear City Council members,
My name is Orly Schube, I'm a junior at Paly and part of the Palo Alto Student Climate Coalition. I'm writing to express my strong support for Palo Alto's Dark Skies Ordinance.

This policy is an opportunity for our city to take meaningful action that benefits people, wildlife, and the environment.

Light pollution has far-reaching effects on both ecosystems and human health. Migrating birds rely on natural light cues from the moon and stars, but excessive artificial light disorients them, leading to collisions with illuminated buildings. Insects, which are critical to healthy food webs, are also fatally attracted to bright, unshielded lighting. By implementing this ordinance, Palo Alto can help reduce bird collisions and insect mortality, restoring balance to local ecosystems along the Pacific Flyway.

Light pollution affects people, too. Studies show that artificial light at night disrupts sleep, circadian rhythms, and hormone balance, and has been linked to insomnia and other health risks. Over-lighting and glare can even make streets less safe by reducing contrast and impairing night vision.

Adopting this ordinance would make Palo Alto a leader in sustainability and environmental stewardship, protecting our skies, wildlife, and our community's well-being.

Thank you for your leadership and for considering this important step toward a healthier, more sustainable future for all of us.

Sincerely,
Orly Schube
Palo Alto High School
Palo Alto Student Climate Coalition
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From: Dashiell Leeds
To: Council, City; Burt, Patrick; Lauing, Ed; Lu, George; Lythcott-Haims, Julie; Reckdahl, Keith; Stone, Greer; Veenker, Vicki; Cha, Kelly; Clerk, City
Cc: James Eggers; Mike Ferreira; Gita Dev; Lait, Jonathan; Armer, Jennifer; Frick, Coleman Subject: SCLP Response to Letter From Stanford Re Nov 10 Dark Sky Ordinance Date: Friday, November 7, 2025 4:38:55 PM
Attachments: SCLP Response to Stanford re Nov 10 Dark Sky Ordinance.pdf CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.

Dear Mayor Lauing and Palo Alto City Councilmembers,
In reviewing the letter sent by Stanford University to the City, the Sierra Club Loma Prieta Chapter has some responses that are relevant to consider as Council deliberates on topics raised by this ordinance. Please read the attached letter for more details.

Sincerely, Dashiell Leeds
Conservation Coordinator
Sierra Club Loma Prieta Chapter

SAN MATEO, SANTA CLARA & SAN BENITO COUNTIES

November 7, 2025 Palo Alto City Council 250 Hamilton Ave Pave ALto, CA 94301 Responses to Comments Received by the City from Stanford Regarding the Draft Dark Sky Ordinance Dear Mayor Lauing and Palo Alto City Councilmembers, In reviewing the letter sent by Stanford University to the City, the Sierra Club Loma Prieta Chapter

has

some

responses

that

are

relevant

consider

Council

deliberates

topics

raised

this

ordinance.

1. Safety concerns regarding motion sensor outdoor lighting are already addressed by

the

ordinance
The letter from Stanford states the following. “Motion-activated lighting does not provide a sense of safety or security, especially in a complex where

tenants

not

have

fixed

closing

hours.

Maintenance,

janitorial,

and

security

staff

are

often

on-site

after

midnight,

and

researchers

and

engineers

regularly

work

late

deadlines

approach.”
We believe that the concerns raised in this letter would already be addressed by the lighting curfew

section

this

ordinance,

which

reads

follows.
“(4) Lighting Control. (A) Lighting Curfew. Unlike other provisions in this section, the Lighting Curfew

shall

apply

all

outdoor

luminaires

for

new

and

existing

buildings

and

structures,

unless

otherwise

approved.

All

outdoor

lighting

shall

fully

extinguished

motion

sensor

operated

12:00

a.m.,

two

hours

after

the

business,

when

people

are

longer

present

exterior

areas,

whichever

later
.”

sierraclub.org/loma-prieta ~ 3921 East Bayshore Road, Suite 204, Palo Alto, CA 94303

The underlined wording of this curfew language is extremely flexible, and allows for consistent lighting

situations

where

people

are

still

present

exterior

areas,

even

after

midnight.

areas

Stanford

where

people

are

regularly

present

after

midnight,

claimed

the

letter,

those

areas

would

allowed

remain

consistently

lit,

according

the

curfew

language

the

ordinance.

The

ordinance

as-written

would

not

require

Stanford

use

motion-sensor

lighting

times

when

people

are

usually

regularly

present

certain

outdoor

areas.

2. The lighting levels established by the ordinance offer sufficient lighting for public safety,

and

avoid

the

hazards

glare

caused

overly

bright

and

‘cool’

lighting.

The letter from Stanford makes the following claim, without citing any scientific studies or specific

evidence.
“Requiring changes such as adding motion sensors, shrouds, or altering fixtures and bulbs would

lead

poor

and

unsafe

lighting

conditions.“
However, DarkSky International’s 2025 State of the Science Report 1 , which is based on an analysis of more than 500 scientific studies regarding artificial light at night, makes the following conclusions

regarding

over-lighting

and

its

negative

effects

public

safety.
“Glare from bright artificial light sources is a particular concern for nighttime safety. It results from

intense

light

rays

entering

the

eye

directly

from

source.

Some

that

light

scatters

inside

the

observer’s

eye,

reducing

the

contrast

between

foreground

and

background.

This

effect

makes

difficult

see

objects

distinct

from

what

surrounds

them.

Glare

reduces

the

visibility

objects

night

for

motorists,

pedestrians

and

bicyclists.

Although

some

older

observers

report

stronger

sensations

glare

from

certain

sources,

seems

affect

people

all

ages
2 .

Some

modern

lighting

sources

LED

can

make

glare

worse

emitting

considerable

light

very

shallow

downward

angles
3 and

also

using

non-uniform

light

sources

with

insufficient

optical

diffusion
4 .

The

perception

glare

seems

vary

with

the

wavelength

light

involved.

general,

short-wavelength

(‘cool’)

light

causes

stronger

glare

than

long-wavelength

(‘warm’)

light
5 .”

5 Bullough,

Spectral

sensitivity

for

extrafoveal

discomfort

glare.

Journal

Modern

Optics,

56(13):1518–1522,

jul

2009.

doi:

10.1080/09500340903045710

4 Yang,

Y.,

Luo,

M.R.

and

Ma,

Assessing

glare.

part

Modifying

unified

glare

rating

for

uniform

and

non-uniform

LED

luminaires.

Lighting

Research

Technology,

49(6):727–

742,

apr

2016.

doi:

10.1177/1477153516642622

3 Kyba,

C.C.M.,

Hänel,

and

Hölker,

Redefining

efficiency

for

outdoor

lighting.

Energy

Environ.

Sci.,

7(6):1806–1809,

2014.

doi:

10.1039/c4ee00566j.

2 Davoudian,

N.,

Raynham,

and

Barrett,

Disability

glare:

study

simulated

road

lighting

conditions.

Lighting

Research

Technology,

46(6):695–705,

nov

2013.

doi:

10. 1177/1477153513510168.

1 https://darksky.org/app/uploads/2025/06/ALAN-State-of-the-Science-2025-EN-2.pdf sierraclub.org/loma-prieta ~ 3921 East Bayshore Road, Suite 204, Palo Alto, CA 94303

The current ordinance, by requiring lights to be fully shielded, prevents the direct light scattering inside

the

observer's

eye

that

would

lead

difficulty

seeing

objects

around

them.

avoiding

short-wavelength

‘cool’

light,

the

ordinance

avoids

the

sources

stronger

glare

that

would

also

reduce

nighttime

visibility.

ensuring

that

lighting

not

unnecessarily

bright

night,

the

ordinance

allows

for

pedestrians

clearly

view

lit

areas

while

maintaining

situational

awareness

their

nighttime

surroundings.

Regarding

motion-sensors,

have

already

established

previously

this

letter

that

the

existing

curfew

language

flexible

allow

for

consistent

lighting

outdoor

areas

where

people

regularly

present

after

midnight.

The ordinance, as written, adheres to the science regarding light pollution and public safety. We are

concerned

that

the

ordinance

modified

allow

for

un-shielded,

brighter,

and

‘cooler’,

lighting,

that

those

modifications

would

actually

have

negative

effect

public

safety,

according

the

scientific

literature

this

subject.

Furthermore, Palo Alto’s Police Department was consulted by the City regarding the standard of 2700

Kelvin

for

lighting

fixtures,

and

found

that

threshold

acceptable

for

public

safety.

3. The ordinance as written establishes clear precedence for state and federal laws. The letter from Stanford makes the following claim. “We are also concerned about potential conflicts with California Title 24 and Cal/OSHA lighting\ requirements.

These

state

and

federal

standards

may

supersede

local

regulations,

rendering

parts

the

proposed

ordinance

unenforceable.

urge

the

City

carefully

evaluate

these

overlaps

avoid

legal

and

practical

inconsistencies.”
The letter does not identify any specific conflicts with state or federal law in the ordinance as written.

Furthermore,

the

ordinance

contains

language

that

already

addresses

these

concerns

the

following

section.
“(i) Additional Provisions and Conflict Precedence. Lighting required by the Building Code, Fire Code,

state

federal

law

shall

additionally

comply

with

the

requirements

this

section,

unless

these

requirements

necessarily

conflict

with

the

aforementioned

Codes

and

laws.

the

event

conflict,

the

standards

the

applicable

Codes

and

laws

shall

prevail.”
Since no specific conflicts with state or federal laws have been identified, and the ordinance clearly

establishes

the

precedence

state

and

federal

laws,

believe

modifications

the

draft

are

necessary

this

time

address

this

topic.

Should

unforeseen

conflicts

arise

after

adoption,

the

ordinance

already

equipped

address

them.

sierraclub.org/loma-prieta ~ 3921 East Bayshore Road, Suite 204, Palo Alto, CA 94303

In Conclusion We hope that our explanations provide sufficient justification that the draft ordinance is already equipped

resolve

the

concerns

from

Stanford

noted

above.

Sincerely,
Dashiell

Leeds
Conservation Coordinator Sierra Club Loma Prieta Chapter sierraclub.org/loma-prieta ~ 3921 East Bayshore Road, Suite 204, Palo Alto, CA 94303

From: Victoria S. Ramirez
To: Council, City
Cc: Cha, Kelly; Molly Swenson (SHC)
Subject: SHC Comment Letter: Item 8 - Lighting Ordinance (11/10/25) Date: Friday, November 7, 2025 4:35:22 PM
Attachments: image001.png
Lighting Ordinance SHC Comment Letter - 11-7-25 FINAL.pdf CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.

Dear Honorable Mayor and members of the City Council,

Attached you will find a letter from Stanford Health Care providing feedback and expressing our concerns with Item 8 on the November 10 Council Meeting Agenda –Proposed Lighting Ordinance.

Please feel free to reach out if you have any questions.

Sincerely,
Victoria

VICTORIA S. RAMIREZ, MPA
she/her/hers
Director of State and Local Government Affairs

Stanford Health Care
Office of Government Affairs – Stanford University
1840 Embarcadero Road
Palo Alto, CA 94303
cell: 650-374-8729
[email protected]
mailing address: 300 Pasteur Drive, M/C 5539, Stanford, CA 94305 Office of Government Affairs

Confidentiality notice: This communication and any attachments may contain confidential or privileged information for the use by the designated recipient(s) named above. If you are not the intended recipient, you are hereby notified that you have received this communication in error and that any review, disclosure, dissemination, distribution or copying of it or the attachments is strictly prohibited. If you have received this communication in error, please contact me and destroy all copies of the communication and attachments. Thank you.

November 7, 2025

Palo Alto City Council
City of Palo Alto
250 Hamilton Avenue
Palo Alto, CA 94301

Re: City Council Consideration of Proposed Lighting Ordinance

VIA EMAIL [email protected]; [email protected]

Dear Mayor Lauing and Members of the City Council,
Stanford Medicine appreciates the opportunity to provide feedback on the current iteration of the proposed Lighting Ordinance. As it relates to our medical campus, we have several concerns with the proposal, particularly related to applicability, safety, implementation costs, and compliance timeline.

We were invited to attend the virtual outreach meeting with Planning staff in October. Based on the verbal comments from our organization and others, there is an overall alignment on concerns and the notion that the business community at large has not been adequately engaged by the City in the crafting of the ordinance compared to proponents of the policy. Based on the review of the most current information, our organization will have great difficulty on multiple fronts in achieving compliance.

With respect to applicability, we assert that the ordinance should be targeted to areas where excessive light has the greatest impact. Considering regulations in other jurisdictions, these would mainly be in hillside and coastal areas; in the City, the Foothills and the Baylands are prime candidates. Urban environments, such as our medical campus, are inherently expected to have additional light for safety and operational purposes.

Regarding safety, as noted by many in October’s outreach meeting, this is a primary concern. As our campus includes hospital uses, our operations run 24/7 and, consequently, adequate lighting is critical.

Internally, prior to recent implementation of exterior lighting upgrades on our campus, we received regular comments from our medical staff that they did not feel safe traversing through the walkways and parking lots on our campus during the nighttime. In addition, we have emergency vehicles, patients, and visitors that rely on our nighttime lighting to navigate to their destinations in an expedient manner. Having to reduce our current overall light output through the measures recommended (motion sensors, shrouding, etc.) would represent a step backward in terms of nighttime safety.

Another comment we echo from the business community is that implementation costs would pose an undue burden on our organization. Implementation would not just constitute the replacement of existing features (i.e. replacing the head of a parking lot light); it would include costly wholesale site lighting redesigns, requiring new light poles, trenching, and landscape restoration. It has been noted by staff that implementation costs for businesses have not been assessed. Having recently engaged in a parking lot lighting upgrade at our 900 Welch Road facility which required significant trenching and installation of new poles, we are aware that lighting installation / modification costs—even for a small property--can cost hundreds of thousands of dollars. Given this is a small sample of our campus, the costs of having to make wholesale changes across the board in a five-year timeframe would be unreasonable.

Finally, the currently proposed ordinance includes a compliance timeline in which all of our lighting would need to meet the new code requirements in five years. This timeline places further financial and operational strain on our organization. For example, additional funds and resources would need to be expended within five years on the new installation at 900 Welch Road to achieve code compliance. We

would ask that the City allow existing lighting to have legal non-conforming status and that the ordinance only apply to new construction projects.

We appreciate your time and consideration of our concerns. We would like to request a continuation of this item so that comments from us and others in the business community can be thoroughly assessed by staff and City Council.

Please do not hesitate to contact me at [email protected] if any questions arise.

Sincerely,

Victoria S. Ramirez Molly Swenson
Director of State and Local Government Affairs Director of Land Use & Licensing Stanford Health Care Stanford Medicine

From: Diane McCoy
To: Council, City
Subject: Fw: Dark Skies Ordinance
Date: Friday, November 7, 2025 4:24:53 PM
CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.
i
----- Forwarded Message -----
From: Diane McCoy <[email protected]>
To: [email protected] <[email protected]> Sent: Friday, November 7, 2025, 04:16:57 PM PST
Subject: Dark Skies Ordinance
Dear Palo Alto City Council.

Thank you very much for your hard work and service.

I have a resident of Palo Alto since 1978.

I live in the Duveneck/St. Francis neighborhood of the city.

I am writing regarding the Dark Skies Ordinance up for discussion on Monday, Nov. 1 city council meeting.

Please adopt a STRONG outdoor lighting ordinance.

A strong ordinance would protect birds, people and our night sky.

Please incorporate the suggestions from the SCVBird Alliance and the Sierra Club in the ordinance.

Have you had a chance to see some of the comments people have written in response to the Palo Alto Weekly's article about the ordinance:
"Dark skies are important to human health because they support a balanced circadian rhythm, improved sleep, hormones and metabolism. Minimally, lightg should be down lit, and softer, rather than blinding white spots lights. " Education for motion detection lights would be excellent. Many have these; they are cost effective and efficient. We have our phones with us all the time; equipped with flashlights!
Thank you for your consideration of this situation.

Best,
Diane McCoy
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From: Victoria S. Ramirez
To: Council, City
Cc: Cha, Kelly; Molly Swenson (SHC)
Subject: SHC Letter of Support Item 8 - Lighting Ordinance (11/10/25) Date: Friday, November 7, 2025 4:13:38 PM
Attachments: image001.png
Lighting Ordinance SHC Comment Letter - 11-7-25 FINAL.pdf CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.

Dear Honorable Mayor and members of the City Council,

Attached you will find a letter from Stanford Health Care providing feedback and expressing our concerns with Item 8 on the November 10 Council Meeting Agenda –Proposed Lighting Ordinance.

Please feel free to reach out if you have any questions.

Sincerely,
Victoria

VICTORIA S. RAMIREZ, MPA
she/her/hers
Director of State and Local Government Affairs

November 7, 2025

Palo Alto City Council
City of Palo Alto
250 Hamilton Avenue
Palo Alto, CA 94301

Re: City Council Consideration of Proposed Lighting Ordinance

VIA EMAIL [email protected]; [email protected]

would ask that the City allow existing lighting to have legal non-conforming status and that the ordinance only apply to new construction projects.

Please do not hesitate to contact me at [email protected] if any questions arise.

Sincerely,

Victoria S. Ramirez Molly Swenson
Director of State and Local Government Affairs Director of Land Use & Licensing Stanford Health Care Stanford Medicine

From: John Miller
To: Council, City
Subject: 11/10/25 Agenda Item 8: Please adopt a strong outdoor lighting ordinance Date: Friday, November 7, 2025 1:53:19 PM
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Dear Mayor Lauing and Members of the City Council,
I am a former resident and frequent visitor to Palo Alto. I’m emailing to ask you to adopt a strong outdoor lighting ordinance to protect wildlife, people and the night sky.

Light pollution in and around the Bay Area has become a serious problem that can impact people by disrupting sleep patterns and can interfere with (if not entirely prohibit) the ability to see and appreciate dark skies.

I urge you to incorporate into the proposed ordinance best practices from the International Dark-Sky Association and the Illuminating Engineering Society, ensuring that outdoor lighting is shielded, controlled and used only where and when it’s needed without compromising safety or commerce.

Thank you for your attention to this most important issue.

John Miller
Los Gatos
From: Annette Herz
To: Council, City
Subject: 11/10/25 Agenda Item 8: Please adopt a strong outdoor lighting ordinance Date: Friday, November 7, 2025 1:44:18 PM
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i
Dear City Council
I am a resident, a certified California Naturalist and a docent at several of our local nature preserves.

I am also VERY concerned about the state of our local environment and the impact our human activity has on them.

As you know the SF Bay Area is a major route for bird migrations - and human population concentrations like the Bay Area Cities can have a disastrous effect on their behaviour.

I noticed even on a much smaller scale the impact (less visitors) my backyard has since the neighbor behind the fence has installed security lights. Less skunks, less raccoons, less fox - but more non-native rats.

For the bird population our city lights is MUCH more dangerous - it can confuse their navigation and lead to avoidance and mistakes that impact not only the single birds, but future generations (a bird that dies on migration will not reproduce..).

With that we have a huge responsibility - and I hope that my city of Palo Alto followed the good example of other cities - and the suggestions set forward by the Bird Alliance and the Sierra Club (both formidable local leaders against climate change and for nature conservation) and PLEASE ADOPT THE STRONGEST ORDINANCE TO PROTECT BIRDS, HUMANS and our NIGHT SKY.

Thanks for making me a proud resident
Annette Herz
--
- Annette
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From: ROBERT HIRT
To: Council, City
Subject: City Council 11/10 meeting:Agenda item 8
Date: Friday, November 7, 2025 1:19:34 PM
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Dear Council:

Please adopt a strong outdoor lighting ordinance and use the suggestions from the Santa Clara Valley Bird Alliance.

Dark skies are very important to protect the many species of birds that migrate primarily at night. Bright lights confuse and disorient them often causing collisions with buildings.

I addition dark skies produce a more restful condition which produces better sleep for our people. It has been shown (by the Cleveland Clinic) that better sleep (a full 8 hrs) is important for keeping immune systems well and which help prevent diseases like cancer from developing.

For the health and happiness of our community please adopt a strong outdoor lighting ordnance.

Very truly yours,
Bob
Bob Hirt
[email protected]
(408) 821-2732
Please excuse the brevity, the typos, and the sometimes humorous autocorrect changes.

From: Margaret Hinebaugh
To: Council, City
Subject: 11/10/25 Agenda Item 8: Please adopt a strong outdoor lighting ordinance Date: Friday, November 7, 2025 11:18:47 AM
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i
Hello,
I strongly urge the Palo Alto City Council to adopt a strong lighting ordinance to protect birds, people, and our night sky from light pollution.

Light pollution harms wildlife and ecosystems, and it disrupts humans' natural circadian rhythms, which has negative impacts on our health. Nighttime lighting is wasteful and unnecessary; we do not need a string of bright, outdoor lights on at every house 24/7. There is no good evidence that increased lighting reduces total crime.

Please incorporate the dark sky/outdoor lighting suggestions from the Santa Clara Valley Bird Alliance and the Sierra Club in the ordinance.

Thank you,
Margaret Hinebaugh
(408) 247-8474
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From: mark conover
To: Council, City
Subject: 11/10/25 Agenda Item 8: Outdoor Lighting Ordinance Date: Thursday, November 6, 2025 11:17:45 PM
CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.

Congratulations on your proposed updated Lighting Ordinance. I have assisted in writing our Santa Cruz lighting ordinance which we submitted to our Mayor in June. Hopefully we will be following in your footsteps.

Following a quick review, I have some comments:

Edgewood Drive Exemption:

As Edgewood Drive borders the sensitive San Fransquito Creek Riparian area, the light limits should not be exempted but if anything strengthened. Our Santa Cruz Lighting Ordinance attempts to limit light trespass on the San Lorenzo River to “unmeasureable”. You should definitely prohibit unapproved luminaires on properties adjacent to the river. A super-bright LED wall pack would be very disruptive to the birds, amphibians, beavers, insects, fish and all other living organisms including the Steelhead Trout and Red Legged Frogs. Regarding security concerns, the 1 lux limit should be adequate for modern security cameras. And motion detection lights would highlight trespasser in the yards.

Shorten compliance period for easily adjustable lights
I suggest shortening the compliance to one year for easily adjustable lights. People tend to procrastinate work until last minute. I doubt that this change would be too much of a burden on the residents. Blanco Texas allowed existing luminaires to be grandfathered in compliance until they were repaired or replaced. Twelve years later “few if any grandfathered lights were voluntarily brought into compliance.” The town passed a new ordinance with a firm date for compliance
Ordinance Name
We started developing a “DarkSky” ordinance but quickly decided to rename it as an “Outdoor Lighting Ordinance”. DarkSky lighting implies limiting lighting toward the sky. But in addition, it is important to limit the light below the horizontal to prevent glare in the eyes of pedestrians, bicyclists, drivers and all living things.

Mark Conover
Santa Cruz CA
From: Timothy Lee
To: Council, City
Subject: 11/10/25 Agenda Item 8: Please adopt a strong outdoor lighting ordinance Date: Thursday, November 6, 2025 10:34:43 PM
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i
Hello Mayor Lauring and Palo Alto city council,
My name is Timothy Lee, a local highschool junior. I, alongside the fushd climate collective and the Santa Clara Valley bird alliance are calling for the strengthening of the dark sky policy in the the city of Palo Alto. I view light pollution to be a harmful force to our society and ecosystem that often goes unrecognized. Light pollution dilutes the night sky, stripping many childhoods from being able to truly experience the stars, limit local astronomical research, and also affects health, causing insomnia, depression, and in some cases, cancer too. This cause can be prevented by the Dark Sky policies strengthening, a relatively low cost policy for a high reward. Please take this matter into consideration.

Sincerely,
Timothy Lee
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From: Kenneth Low
To: Council, City
Subject: Proposed Outdoor Lighting Ordinance
Date: Thursday, November 6, 2025 7:44:23 PM
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i
Dear Honorable Mayor and Members of the City Council,

With respect to the proposed lighting ordinance, we are writing in support of the Edgewood Neighborhood Alliance and the following:

We support the exemption of homes on the creek-side of Edgewood Drive given their unique circumstances, including encampments in the creek, crime and proximity to East Palo Alto, which has no barriers to enter the creek.

The exemption for Edgewood properties contains an error and should be corrected to the following:

Thank you.

Kenner Low
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From: Sherry Listgarten
To: Council, City; Cha, Kelly
Subject: Strongly in favor of dark(er) skies
Date: Thursday, November 6, 2025 7:35:31 PM
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Dear City Council and Staff,
I am very supportive of stronger limits on outdoor lighting, which you will be considering on November 10. Light pollution is bad for our health and that of birds, insects, and the fauna that depend on them. Many essential natural behaviors like breeding, foraging, and migration rely on dark nights. But too many of our streets and yards are now unnecessarily lit up at all hours.

This is a relatively new phenomenon for our city. The pervasiveness of LED lighting has caused Palo Alto to become much lighter at night, with an almost industrial-quality tone. LED lights are inexpensive to operate and often blue-ish in color, which is leading to unhealthy levels of outdoor light pollution. A good ordinance will get us back to our more natural norm, at least over time.

I agree with the Sierra Club and SCV Bird Alliance that the ordinance should apply to all new and replacement lighting, but not to existing fixtures that would not otherwise need replacing. I also agree that a one-year (and not two-year) heads-up period of education about adjusting timers/angles/etc should be sufficient, particularly since enforcement will largely consist of more education anyway.

One thing I would suggest is to consider a shut-off period of 11pm or 11:30pm rather than midnight, simply because midnight is difficult for a lot of people to set correctly on timers.

This is a relatively small but powerful and hopefully visible thing that Palo Alto can do to better support the people and the wildlife in our city.

Thank you,
-- Sherry.

From: Daniel Hansen
To: Council, City; Lauing, Ed; Cha, Kelly
Cc: Francois, Matthew; Lait, Jonathan; Armer, Jennifer; Shikada, Ed; Stump, Molly; Cha, Kelly Subject: Proposed Lighting Ordinance (18.40.250)
Date: Thursday, November 6, 2025 4:35:37 PM
Attachments: Letter Regarding Lighting Ordinance - Edgewood Exemption.pdf CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.
i
Dear Honorable Mayor, Members of the City Council and Ms. Cha,

Please see the attached letter submitted on behalf of the Edgewood Neighborhood Alliance regarding the Proposed Lighting Ordinance (18.40.250).

Best regards,

Daniel Hansen

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Via Email
[[email protected]; [email protected]; [email protected]] November 6, 2025
Honorable Mayor and Members of the City Council and Kelly Cha City of Palo Alto
250 Hamilton Avenue
Palo Alto, CA 94301
Re: Updating Section 18.40.250 (Lighting), Amending Chapters 18.10, 18.12, 18.28, and Section 18.40.230 of Title 18; Agenda Item # 8 City Council, Regular Meeting, November 10, 2025
Dear Honorable Mayor and Members of the Palo Alto City Council and Ms. Cha:

At the City Council meeting on April 7, 2025, the Council unanimously agreed that the creek-side properties on Edgewood Drive should be excluded from the security elements of the proposed lighting ordinance due to their unique circumstances, including encampments in San Francisquito Creek and proximity to East Palo Alto. The revised ordinance in Staff’s report includes this exemption; however, it contains an error. As drafted, only 15 of the 52 properties on Edgewood Drive would be excluded.

Specifically, the “if” language that refers to reconfiguring a portion of the site subject to a 2002 easement has no bearing in this context and would unfairly restrict the exemption. Here is the error:
(7) Single family residential sites adjacent to San Francisquito Creek and fronting on Edgewood Drive if the portion of the site subject to a permanent easement in favor of the Santa Clara Valley Water District (or its successor in interest) for flood control purposes is reconfigured after January 1, 2002. These sites shall be subject to the requirements under Section 18.40.250(e)(4)(A).

The added language was apparently copied from the City’s fencing ordinance (PAMC

16.24.020(d)) where the flood control context is relevant. It should be removed so that the Council’s intent can be accomplished.

Respectfully,

EDGEWOOD NEIGHBORHOOD ALLIANCE
By, its representative,
_____________________
Daniel Hansen

cc: Matthew D. Francois, Rutan & Tucker, LLP
Jonathan Lait, Director of Planning & Development Services Jennifer Armer, Assistant Director of Planning & Development Services Ed Shikada, City Manager
Molly Stump, City Attorney

From: Dashiell Leeds
To: Council, City; Burt, Patrick; Lauing, Ed; Lu, George; Lythcott-Haims, Julie; Reckdahl, Keith; Stone, Greer; Veenker, Vicki; Cha, Kelly; Clerk, City
Cc: [email protected]; James Eggers; Mike Ferreira; Gita Dev; Lait, Jonathan; Armer, Jennifer; Frick, Coleman
Subject: SCLP and SCVBA Comments on Nov 10 Draft Dark Sky Ordinance Date: Thursday, November 6, 2025 4:10:39 PM
Attachments: SLCP SCVBA joint letter to Palo Alto re Dark Sky Ordinance Nov 10, 2025.pdf CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.

Dear Mayor Lauing and Palo Alto City Councilmembers,
The Santa Clara Valley Bird Alliance and the Sierra Club Loma Prieta Chapter support the adoption of Palo Alto’s Dark Sky (Outdoor Lighting) Ordinance, and suggest a few critical corrections. We appreciate the extensive work by City staff, and the clear direction from the Planning and Transportation Commission and Council to develop a measure that protects migratory birds, nocturnal wildlife, and human health while conserving energy and restoring the City’s night sky.

The ordinance follows best practices from DarkSky International and the Illuminating Engineering Society by ensuring that lighting is shielded, directed, and used only where and when needed. Please consider incorporating the following four requests:

Amend Section 18.40.250(c)(3) to remove the phrase “If a building permit is required” to apply the ordinance to all new installation, replacement, or modification of outdoor luminaires,
Amend Section 18.40.250(d)(7) to ensure that prohibited lighting types are not allowed in the exempted Edgewood Drive properties,
Remove 18.40.250(L)(2)(A)(B), removing retrofit requirements for existing outdoor lighting, and
Retain and shorten the compliance period in Section 18.40.250(L)(1) for easily adjustable existing lighting fixtures to one year.

Please read the attached letter for more details regarding our suggested improvements.

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

SAN MATEO, SANTA CLARA & SAN BENITO COUNTIES

November 6, 2025 Palo Alto City Council 250 Hamilton Ave Palo Alto, CA 94301 Re: November 10 Agenda Item 8 - Dark Sky (Outdoor Lighting) Ordinance Dear Mayor Lauing and Palo Alto City Councilmembers, The Santa Clara Valley Bird Alliance and the Sierra Club Loma Prieta Chapter support the adoption

Palo

Alto’s

Dark

Sky

(Outdoor

Lighting)

Ordinance,

and

suggest

few

critical

corrections.

appreciate

the

extensive

work

City

staff,

and

the

clear

direction

from

the

Planning

and

Transportation

Commission

and

Council

develop

measure

that

protects

migratory

birds,

nocturnal

wildlife,

and

human

health

while

conserving

energy

and

restoring

the

City’s

night

sky.

The ordinance follows best practices from DarkSky International and the Illuminating Engineering

Society

ensuring

that

lighting

shielded,

directed,

and

used

only

where

and

when

needed.

Please

consider

incorporating

the

following

four

requests:

● Amend Section 18.40.250(c)(3) to remove the phrase “If a building permit is required” to

apply

the

ordinance

all

new

installation,

replacement,

modification

outdoor

luminaires,
● Amend Section 18.40.250(d)(7) to ensure that prohibited lighting types are not allowed in the

exempted

Edgewood

Drive

properties,
● Remove 18.40.250(L)(2)(A)(B), removing retrofit requirements for existing outdoor lighting,

and
● Retain and shorten the compliance period in Section 18.40.250(L)(1) for easily adjustable existing

lighting

fixtures

one

year.

Request #1
Amend Section 18.40.250(c)(3) to remove the phrase “If a building permit is required” to apply

the

ordinance

all

new

installation,

replacement,

modification

outdoor

luminaires.

Current text
(3) If a building permit is required: New installation of outdoor luminaires, replacement of

existing

outdoor

luminaires,

modifications

the

lighting

type

system.

Proposed Text
(3) If a building permit is required: New installation of outdoor luminaires, replacement

existing

outdoor

luminaires,

modifications

the

lighting

type

system.

Justification

Both

the

Planning

and

Transportation

Commission

(October

30,

2024)

and

the

City

Council

(April

2025)

explicitly

directed

that

the

lighting

standards

apply

all

new

and

replacement
outdoor lighting. The April 7th City Council minutes 1 and the staff report for Item 8 confirm this directive, yet the draft ordinance retains the inconsistent “building permit” qualifier.

Limiting applicability to projects requiring a building permit creates a major loophole that exempts

most

fixture

replacements

and

new

lighting

installations.

Since

lighting

installations

not

typically

require

permits,

much

new

and

replacement

lighting

would

remain

unregulated.

Removing

the

“building

permit”

qualifier

will

bring

the

ordinance

into

alignment

with

Council

direction

and

ensure

functions

intended.

Request #2 Amend Section 18.40.250(d)(7) to ensure that prohibited lighting types are not allowed in the

exempted

Edgewood

Drive

properties.

Current Text
“(7) Single family residential sites adjacent to San Francisquito Creek and fronting on

Edgewood

Drive

the

portion

the

site

subject

permanent

easement

favor

the

Santa

Clara

Valley

Water

District

(or

its

successor

interest)

for

flood

1 https://cityofpaloalto.primegov.com/Public/CompiledDocument?meetingTemplateId=16025&compileOutpu tType=1
control purposes is reconfigured after January 1, 2002. These sites shall be subject to the

requirements

under

Section

18.40.250(e)(4)(A).”

Proposed Text
(7) Single family residential sites adjacent to San Francisquito Creek and fronting on Edgewood

Drive

the

portion

the

site

subject

permanent

easement

favor

the

Santa

Clara

Valley

Water

District

(or

its

successor

interest)

for

flood

control

purposes

reconfigured

after

January

2002.

These

sites

shall

subject

the

requirements

under

Sections

18.40.250(e)(4)(A)

and

18.40.250(g)
.

Justification While we appreciate that Section 18.40.250(e)(4)(A) applies the lighting curfew, the exemption in

(d)(7)

inadvertently

allows

the

use

prohibited

lighting

such

blinking,

flashing,

rotating

lights,

and

searchlights,

aerial

lasers,

spotlights,

all

forms

illumination

that

are

unnecessary

for

safety

and

highly

disruptive

wildlife.

Safety

can

achieved

using

fully

shielded,

dark-sky-compliant

luminaires.

Extending

the

prohibited

lighting

clause

this

area

will

prevent

excessive

glare

and

protect

one

Palo

Alto’s

most

sensitive

riparian

corridors

along

San

Francisquito

Creek.

Request #3
Remove retrofit requirements in (L)(2) for existing outdoor lighting.

Current Text (Section 18.40.250(L))
“(L) Existing Nonconforming Lighting (1) Within two years of [the effective date of this ordinance]: Where existing outdoor luminaires

have

the

ability

adjust

(through

existing

dimmers,

directional

adjustability,

timers,

etc.),

the

requirements

under

Section

18.40.140(e),

except

for

the

shielding

requirements

under

subsection

18.40.140(e)(1),

shall

apply.
(2) For all existing outdoor luminaires, the requirements under Section 18.40.140(e) shall apply

within

the

following

timeframes

from

[the

effective

date

this

ordinance]:
(A) Residential and Mixed Use Zoning Districts: Within ten years. (B) Nonresidential Zoning Districts: Within five years.

Proposed Revision
Keep (L)(1) to retain the requirement that all easily-adjustable luminaires be adjusted to be

compliant

with

the

ordinance.

recommend

adjusting

the

timing

window

(l)(1),

described

below

Request

#4.

Delete subsections (L)(2)(A) and (B), removing the retrofit schedule. (2) For all existing outdoor luminaires, the requirements under Section 18.40.140(e) shall apply

within

the

following

timeframes

from

[the

effective

date

this

ordinance]:
(A) Residential and Mixed Use Zoning Districts: Within ten years. (B) Nonresidential Zoning Districts: Within five years.

Justification
Requiring retrofits for all existing lighting would be difficult to administer and monitor, and can create

hardship

for

residents

and

businesses.

Applying

the

ordinance

all

new,

replacement,

and

easily-modified

lighting

would

achieve

gradual

citywide

compliance

through

equipment

turnover

while

avoiding

confusion

and

unnecessary

administrative

burden.

Retaining the hardship exemption (Section 18.40.250(j)) and clear applicability to all new and replacement

lighting

ensures

that

future

installations

meet

dark-sky

standards

without

imposing

mandatory

retrofits

existing

luminaires.

Request #4
Shorten the compliance period for easily adjustable existing lighting fixtures.

Current Text (Section 18.40.250(L)(1))
“(1) Within two years of [the effective date of this ordinance]: Where existing outdoor

luminaires

have

the

ability

adjust

(through

existing

dimmers,

directional

adjustability,

timers,

etc.),

the

requirements

under

Section

18.40.140(e),

except

for

the

shielding

requirements

under

subsection

18.40.140(e)(1),

shall

apply.”

Proposed Text
“(1) Within one year of [the effective date of this ordinance]: Where existing outdoor

luminaires

have

the

ability

adjust

(through

existing

dimmers,

directional

adjustability,

timers,

etc.),

the

requirements

under

Section

18.40.140(e),

except

for

the

shielding

requirements

under

subsection

18.40.140(e)(1),

shall

apply.”

Justification
A two-year grace period is unnecessarily long for fixtures that can be corrected through simple adjustments

such

dimming,

re-aiming,

resetting

timers.

Comparable

Dark

Sky

ordinances,

including

Brisbane’s,

require

compliance

within

one

year.

one

year

window

provides

sufficient

time

for

the

City

distribute

educational

materials

and

for

property

owners

make

straightforward

adjustments,

achieving

measurable

reductions

light

pollution

much

sooner.

In Conclusion With the brief but critically important modifications we have suggested, Palo Alto’s dark sky ordinance

will

reduce

light

pollution

over

time

and

improve

public

health

and

public

safety

and

protect

migratory

birds

and

wildlife.

The

provisions

this

ordinance

are

line

with

successfully

adopted

dark

sky

ordinances

throughout

the

nation.

The

requirements

are

extremely

flexible,

ensuring

that

business

Palo

Alto

will

not

impeded,

and

are

robust

enough

protect

residents

and

wildlife

from

the

dangers

over-lighting.

Please

move

adopt

this

ordinance,

with

the

modifications

have

suggested.

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

From: Shannon McEntee
To: Council, City
Subject: Agenda Item 8, Please Adopt a Strong Outdoor Lighting Ordinance Date: Thursday, November 6, 2025 10:45:28 AM
CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.

Dear Mayor Lauing and council members:

Being a passionate environmentalist I’ve known for a long time how night light endangers species, including humans! Every night I sleep with an eye cover because the street lamp outside my condo building penetrates into my bedroom.

Other cities have Dark Sky Ordinances so we are behind in this simple protection. Please do the right thing and protect our neighboring species, including me and fellow residents. Our world is changing so fast — we need to keep up.

Thank you for your all your good work in managing our special city. You have my deep respect and admiration.

Sincerely,
Shannon Rose McEntee
From: Tracy Ferea
To: Council, City
Subject: Please Pass a Strong Dark Skies Ordinance 11/10/25 Agenda Item 8 Date: Wednesday, November 5, 2025 6:31:52 PM
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i
Dear Council,
As a PhD Biologist I would like to ask you to pass a strong scientific based Dark Skies Ordinance. Light pollution is one of the fastest growing and most pervasive forms of environmental pollution. Scientific research suggests that light pollution can have lasting adverse effects on both human and wildlife health. My family deals with this pollution nightly as our neighbors and a Church shine light into our house and yard.

Some of the Many Specific Human Health Impacts
Sleep disorders: Lack of darkness can lead to sleep deprivation and disorders like insomnia and delayed sleep-phase syndrome.

Mental health: It is linked to depression and impaired thinking.

Hormonal disruption: Artificial light at night can suppress the production of melatonin, which is essential for regulating metabolism, the immune system, and sleep.

Cardiovascular problems: Nighttime light exposure has been linked to higher risks of heart disease, high blood pressure, and increased stress- related activity in the brain.

Metabolic issues: Studies have linked light at night to an increased risk of obesity and diabetes.

Cancer risk: Lowered melatonin levels, which are a consequence of nighttime light exposure, have been correlated with increased rates of some cancers, such as breast cancer.

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Vision problems: Direct glare from bright, poorly designed lights can impair vision, reduce sensitivity to fine details, and cause safety issues, particularly for the elderly.

Melatonin production: Melatonin is a hormone released in the dark that is vital for sleep and has protective health functions.

Circadian rhythms: The human body relies on a natural day-night cycle to keep internal rhythms in sync. Artificial light at night disrupts this cycle.

Negative Impacts on Wildlife and the Environment
Disruption of circadian rhythms: Artificial light can interfere with the natural day- night cycle, affecting the sleep patterns and feeding habits of animals.

Misorientation and collisions: Bright lights can confuse migratory animals and birds, leading them off course and into dangerous situations.

Altered predator-prey relationships: Artificial light can make nocturnal animals more visible to predators, disrupting their natural patterns.

Loss of biodiversity: Light pollution can drive away sensitive wildlife species, reducing the biodiversity of ecosystems.

Altered plant growth: Artificial light can affect the growth and flowering patterns of plants, potentially disrupting plant-animal interactions.

Increased leaf toughness: Leaves exposed to artificial light at night are often physically tougher and more difficult for insects to chew, disrupting the basis of the food web.

Resource allocation: Plants may shift resources from producing nutrient-rich leaves to supporting structural compounds, leading to lower nutrient levels in leaves decreasing the nutrient value in the food web.

Light pollution poses a significant threat to both ecosystems and human health. The good news is that you as council members have the power to reduce its impact and improve both our health and that of our environment. It is time to take action now and bring back the darkness for a healthier, more sustainable future for us all.

Sincerely,
Tracy Ferea, PhD
From: Niu, Isabelle
To: Council, City
Subject: 11/10/25 Agenda Item 8: Please adopt a strong outdoor lighting ordinance Date: Wednesday, November 5, 2025 4:32:02 PM
CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.
i
Hi Palo Alto City Council,
My name is Isabelle Niu and I am a high school junior in the Bay Area. As a student deeply interested in astronomy and our environment, I wanted to advocate for the adoption of a strong lighting ordinance to protect birds, people, and our night sky.

Being someone who loves to visit Palo Alto facilities (Palo Alto library, Stanford mall, etc.), I've noticed that while the city already does better than many areas in limiting skyglow, there are still places where lights are brighter than needed or shine upward rather than toward the ground. Some fixtures also illuminate trees directly, which can disrupt their natural growth cycles and harm overall plant health. Simple changes like setting standards for adding shielding, lowering brightness, and ensuring lights point only where illumination is needed can maintain safety while reducing unintended environmental impacts.

Thank you so much for your time and consideration.

Warm regards,
Isabelle Niu
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From: Michael Hindery
To: Council, City
Subject: 11/10/25 Agenda item 8: please adopt a strong outdoor lighting ordinance Date: Wednesday, November 5, 2025 3:09:06 PM
CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.
i
Hi -- I am a 30 year Palo Alto resident and am writing to urge the Council pass a strong outdoor lighting ordinance at next week's meting. We need the Dark Sky Ordinance to reduce light pollution and maintain the ability to see the stars.

Thank you.

Michael Hindery
m: 650-740-0004
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From: Kay Bushnell
To: Council, City
Subject: 11/10/25 Agenda item 8
Date: Wednesday, November 5, 2025 12:45:04 PM
Dear Mayor Lauing and members of the Palo Alto City Council, Please establish a strong Dark Sky Ordinance (outdoor lighting ordinance). It is an important way to benefit both human and wildlife well-being.

We must prevent Palo Alto's natural darkness from being polluted with unhealthy artificial lighting. Please remember that we are city that
often serves as a role model for other communities. Our strong Dark Sky Ordinance may benefit them, too.

Thank you,
Kay Bushnell
Palo Alto, CA
From: Cha, Kelly
To: Tiffany Griego; Council, City; Clerk, City
Cc: Shweta Bhatnagar; Diana O"Dell; Jean G. Snider; Kelly Kline; Jamie S. Jarvis; Inglis, Jim Subject: Re: Stanford Comments: 11/10/25 City Council Hearing on the Lighting Ordinance Update Date: Wednesday, November 5, 2025 11:51:55 AM
Attachments: Outlook-a1naulif.png
Hi Ms. Griego,
Thank you for taking time and submitting comments. This email acknowledges that the City received your comments and that your comment letter will be shared as part of the public comments for the upcoming hearing on 11/10.

Thanks,
Kelly Cha (she/her)
Senior Planner
Planning and Development Services
(650) 329-2155 | [email protected]
www.PaloAlto.gov

From: Tiffany Griego <[email protected]>
Sent: Tuesday, November 4, 2025 2:24 PM
To: Cha, Kelly <[email protected]>; Council, City <[email protected]>; Clerk, City <[email protected]>
Cc: Shweta Bhatnagar <[email protected]>; Diana O'Dell <[email protected]>; Jean G.

Snider <[email protected]>; Kelly Kline <[email protected]>; Jamie S. Jarvis <[email protected]>; Inglis, Jim <[email protected]> Subject: Stanford Comments: 11/10/25 City Council Hearing on the Lighting Ordinance Update

CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.

Dear Mayor Lauing and Members of the City Council,

Please find enclosed Stanford University’s comments related to the Dark Sky Lighting Ordinance as it affects Stanford Research Park.

Thank you in advance for your efforts to respond to these comments.

Respectfully submitted,

Tiffany Griego
Senior Managing Director, Stanford Research Park

Take advantage of our transportation programs:
www.SRPgo.com, a service of Stanford Research Park

From: Cha, Kelly <[email protected]>
Sent: Friday, October 31, 2025 10:54 AM
Cc: Cha, Kelly <[email protected]>
Subject: 11/10/25 City Council Hearing on the Lighting Ordinance Update

Hi everyone -

Thank you for your continued interest and participation in the Lighting Ordinance Update effort. The Lighting Ordinance Update item is scheduled for the upcoming City Council Hearing on November 10, 2025. Please review the staff report and associated attachment from the City Council Meeting Agenda page here
. The Lighting Ordinance Update is Item #8 on the agenda.

Please review the PUBLIC COMMENTS section of the agenda to find out how to send your written comments in advance of the meeting, and how to participate and provide your comments orally in- person and virtually.

As always, if you have any questions or problem accessing the staff report and associated attachments for the Lighting Ordinance Update item, please do not hesitate to contact me.

Thanks again for your continued interest and participation in this effort,

Kelly Cha (she/her)
Senior Planner
Planning and Development Services
(650) 329-2155 | [email protected]
www.PaloAlto.gov

From: [email protected]
To: Council, City; Council, City
Subject: 11/10/25 Agenda Item 8: Please adopt a strong, science-based Dark Sky Ordinance Date: Wednesday, November 5, 2025 6:51:06 AM
CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.
i
Dear Mayor Lauing and City Council Members,

I urge you to adopt a Dark Sky (outdoor lighting) Ordinance. Establishing this ordinance would help protect migrating birds, nocturnal wildlife, and human health, while saving energy and restoring our view of the stars.

Artificial light at night affects every level of food webs and ecosystems. We are located on the Pacific Flyway used by migrating birds. Artificial light disorients them, drawing them into urban areas when collisions are often fatal. Insects are irresistibly drawn to lights, where they circle until they die of exhaustion. Because insects are vital prey for birds and other wildlife, insect declines ripple up the food web. Controlling outdoor lighting can reduce bird and insect mortality and restore healthier ecosystems along the Pacific Flyway.

Artificial light harms people too. Artificial light at night disrupts sleep, mood, and hormone balance, and has been linked to insomnia, depression, metabolic disease, and cancer risks.

Glare from over-lighting can make streets less safe by reducing contrast and night vision.

I live in the Palo Verde neighborhood of Palo Alto in a community of Eichler Houses. The houses have beautiful ceiling to floor glass windows as exterior walls. At night, the lights from my neighbor’s back yard aim upwards and towards our house. They are so bright -- all the trees are “lit up” and it looks like a spotlight is aimed over the fence and into our windows.

After the neighbors go to bed, these lights are set to go off as motion sensors. When something moves in their yard at night, I get woken by the glaring light coming through my windows.

Besides interrupting my sleep, it can’t be good for the other living creatures in the neighborhood.

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I hope you will consider all the health benefits, energy savings, and safety attributes of adopting the best practices from the International Dark-Sky Association and the Illuminating Engineering Society.

Warm regards,
Karen Rohde
3360 Thomas Drive, Palo Alto, CA 94303

2025-2026 President, The Woman’s Club of Palo Alto
Past President, the Rotary Club of Palo Alto

Sent from Outlook

From: Peter Coughlan
To: Council, City
Subject: 11/10/25 Agenda item 8: please adopt a strong outdoor lighting ordinance Date: Tuesday, November 4, 2025 7:45:09 PM
CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.

I live on Mariposa Avenue. A street lamp shines directly into my bedroom, even through a dark cloth curtain.

I understand the benefit of street lamps (reduced crime, safe walking, etc., but perhaps Palo Alto could adopt lampshades that keep the cone of light from spreading so broadly, and lamps that are a bit gentler on the eyes.

Thanks for your consideration,
Peter Coughlan
Homeowner
Mariposa Avenue
From: Carolyn Davidson
To: Council, City
Subject: 11/10/25 Agenda Item 8: Please adopt a strong outdoor lighting ordinance Date: Tuesday, November 4, 2025 6:51:51 PM
CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.
i
Dear members of the Palo Alto City Council,
I am a Palo Alto resident, a grandparent, a birding enthusiast, and someone interested in the constellations.

I urge you to pass a strong, science-based ordinance to protect birds (and people) and to make the constellations a bit more visible from my yard, where I enjoy trying to find them after dark. I'd love to introduce my grandchildren to the stars, their patterns, and the stories behind the constellations. A little less ambient light would be a big help! Looking forward to learning that you've passed a strong outdoor lighting ordinance.

Best regards,
Carolyn Davidson
1919 Barbara Drive
Palo Alto. 94303
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From: Tiffany Griego
To: Cha, Kelly; Council, City; Clerk, City
Cc: Shweta Bhatnagar; Diana O"Dell; Jean G. Snider; Kelly Kline; Jamie S. Jarvis; Inglis, Jim Subject: Stanford Comments: 11/10/25 City Council Hearing on the Lighting Ordinance Update Date: Tuesday, November 4, 2025 2:25:12 PM
Attachments: 2025-11-04__ Comment Ltr Dark Sky Ordinance - Stanford University.pdf CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.

Dear Mayor Lauing and Members of the City Council,

Please find enclosed Stanford University’s comments related to the Dark Sky Lighting Ordinance as it affects Stanford Research Park.

Thank you in advance for your efforts to respond to these comments.

Respectfully submitted,

Tiffany Griego
Senior Managing Director, Stanford Research Park

Take advantage of our transportation programs:
www.SRPgo.com, a service of Stanford Research Park

From: Cha, Kelly <[email protected]>
Sent: Friday, October 31, 2025 10:54 AM
Cc: Cha, Kelly <[email protected]>
Subject: 11/10/25 City Council Hearing on the Lighting Ordinance Update

Hi everyone -

Please review the PUBLIC COMMENTS
section of the agenda to find out how to send your written comments in advance of the meeting, and how to participate and provide your comments orally in- person and virtually.

As always, if you have any questions or problem accessing the staff report and associated attachments for the Lighting Ordinance Update item, please do not hesitate to contact me.

Thanks again for your continued interest and participation in this effort,

Kelly Cha (she/her)
Senior Planner
Planning and Development Services
(650) 329-2155 | [email protected]
www.PaloAlto.gov

1 of 1

November 4, 2025
Palo Alto City Council
City of Palo Alto
250 Hamilton Avenue
Palo Alto, CA 94301

Re: City Council Consideration of Lighting Ordinance

VIA EMAIL [email protected]

Dear Mayor Lauing and Members of the City Council,

We would like to extend our sincere thanks to the City Council for the opportunity to provide feedback on the proposed changes to the Lighting Ordinance. As the landowner of Stanford Research Park, we are concerned that the proposed Lighting Ordinance pose s substantial design and implementation challenges for both the University and our tenants in the Research Park area.

We attended the October webinar outreach meeting that was organized by the Chamber and City staff to engage with business owners. We echo many of the concerns shared by fellow owners and tenants during the discussion. Based on our preliminary review, we believe that it may not be feasible to comply with the proposed standards while also maintaining the safety, security, and regulatory compliance that are essential to our operations and responsibilities as a property owner.

Safety Considerations: Outdoor lighting in the Research Park is intentionally designed to provide consistent and adequate coverage based on fixture type, bulb strength, and layout. Requiring changes such as adding motion sensors, shrouds, or altering fixtures and bulbs would lead to poor and unsafe lighting conditions. Motion-activated lighting does not provide a sense of safety or security, especially in a complex where tenants do not have fixed closing hours. Maintenance, janitorial, and security staff are often on -site after midnight, and researchers and engineers regularly work late as deadlines approach. This could also apply to future tenants. A low-lit campus, particularly with motion sensors, would feel unsafe and unwelcoming at night. This is also concerning as it relates to parking garages, where consistent lighting is essential for visibility and security . We urge the City to reconsider these proposed requirements and allow more flexibility for multi-tenant office sites.

Implementation Costs: The commercial office market is already under significant stress, and the proposed lighting standards would place an added burden on property owners. Upgrading lighting can be costly and may require extensive parking lot redesign, including relocating light poles and trenching to modify concrete, asphalt, trees, utilities, and drainage systems. We urge the Council to consider the financial and practical impacts on property owners and explore more flexible approaches to implementation.

Policy Standards and Regulatory Alignment : Retrofitting existing lighting fixtures for Dark Sky compliance requires a qualified lighting designer to ensure all specifications are properly met. This process includes conducting photometric studies to achieve correct lighting levels, ensuring JA8 and Title 24 compliance, meeting ADA requirements, and incorporating a 3000 Kelvin LED light source for improved visual acuity. To provide more detail: a light source with a color temperature of 2700 Kelvin, while ideal for indoor settings, appears too yellow for nighttime outdoor environments. This warmer tone can reduce visual acuity and is not suitable for an outdoor environment that is based on a bluer light. Conversely, color temperatures above 3000 Kelvin tend to appear too blue. A 3000 Kelvin light, which produces a neutral white tone, is considered optimal according to studies. Considering this, Stanford respectfully requests that the maximum allowable standard be adjusted to 3000 Kelvin. This adjustment would also ensure greater product availability and flexibility in meeting the ordinance.

We are also concerned about potential conflicts with California Title 24 and Cal/OSHA lighting requirements. These state and federal standards may supersede local regulations, rendering parts of the proposed ordinance unenforceable. We urge the City to car efully evaluate these overlaps to avoid legal and practical inconsistencies.

Finally, the current proposal would require all properties to come into full compliance within five years of the ordinance’s effective date. This timeline may place an undue burden on property owners, particularly given the costs and logistical complexity involved . We re quest that the City exempt existing buildings and apply the new standards only to new construction projects.

We want to encourage the City to keep Palo Alto attractive to business and appreciate the City Council’s thoughtful consideration of our comments. Please reach out to our team with any questions. We appreciate your consideration, and please let me know if you have further questions at [email protected]

Sincerely,

Tiffany Griego
Senior Managing Director, Commercial Real Estate
Stanford Real Estate, Stanford University
[email protected]

cc: Jonathan Lait, Director of Planning and Development Services Jennifer Armer, Assistant Director, Planning and Development Services Coleman Frick, Long-Range Planning Manager, Planning and Development Services Kelly Cha, Senior Planner, Planning and Development Services

Palo Alto City CouncilNovember 10, 2025

Palo Alto City Council
November 10, 2025