Agenda packet — Palo Alto City Council, December 8, 2025 (part 2 of 2)

Management
Response
Responsible Department(s): CSD
Concurrence: Agree
Target Date: March 31, 2026

Corrective Action Plan: CSD will develop a policy for receiving and storing certain equipment and materials. The policy will establish criteria on the types of equipment and materials that should be included in the inventory management system. This could be based on items of certain value or type (e.g., electronics and tools).

Additional
Observation:

The current
practice of using
the Capital
Improvement
Process (CIP) to
replace
equipment is
burdensome.

The current process for replacing equipment at CSD is to go through the City’s Capital Improvement Process (CIP). This process can take months. Several staff at CSD noted that each time a substantial piece of equipment fails, they are often without use of that item for an extended period of time due to having to go through the City’s CIP process. Staff stated that it would be helpful if the Department had funds that could be applied for such purchases.

Based on discussions with management, with implementation of a comprehensive equipment inventory that includes estimated replacement timelines and costs, funding for replacement of equipment could be planned during the annual budget development process. During this process, the department can appropriate funding for routine equipment replacement and a reasonable amount of unanticipated replacement costs, as the City monetary/fund balance permits. Planning, foresight, and funding may contribute to more efficient replacement and fewer extended periods of downtime with no equipment.

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13 Item 14
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1 November 5, 2025
City of Palo Alto
Office of the City Auditor
Building Permit and Inspection Fees
Audit
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Contents
Baker Tilly Advisory Group, LP and Baker Tilly US, LLP, trading as Baker Tilly, operate under an alternative practice structure and are members of the global network of Baker Tilly International Ltd., the members of which are separate and independent legal entities. Baker Tilly US, LLP is a licensed CPA firm that provides assurance services to its clients. Baker Tilly Advisory Group, LP and its subsidiary entities provide tax and consulting services to their clients and are not licensed CPA firms.

Executive Summary ............................................................................................................................ 1 Introduction ........................................................................................................................................ 4 Detailed Analysis ................................................................................................................................. 7 Audit Results ..................................................................................................................................... 10

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1 Executive Summary
Purpose of the Audit
Baker Tilly Advisory Group, LP (Baker Tilly), in its capacity serving as the Office of the City Auditor (OCA) for the City of Palo Alto (the City), conducted a Building Permit and Inspection Fees Audit based on approved Task Order 4.30 as part of the City’s FY25 Audit Plan. The objectives of this audit were to:
• Determine If the City’s building permit and inspection fees are accurately and consistently applied.
• Evaluate the administration of the Development Services Program for adequate internal controls to safeguard the City from fraud, waste, and abuse.

Report Highlights
Finding 1:
(Page 10)
Overall, fee assessments for most major fees were accurately assessed, but some smaller fees were not applied consistently across all transactions.

The City’s Planning and Development Services Department (PDS) provides building permit and inspection services for residential, commercial and mixed- use building projects. The City’s Municipal Fee Schedule establishes the annual fees that will be charged for these services. In FY23 and FY24, there were a total of 4,774 projects reviewed by the Development Services Center and 7,686 building permits issued. The Development Services Center collected approximately $15 million in revenue in FY23 and $17 million in FY24. OCA tested a sample of building permit types and inspection fees for accuracy and consistency.

While most major fees were accurately assessed, OCA found several smaller fees were not consistently applied. In a few cases
, fee errors resulted in
overcharging customers, but most errors resulted in customers being undercharged.

Building Permit Fees
Out of 60 sampled projects, OCA identified two projects (3%) with inappropriately applied fees. One project was not charged a fire plan check fee resulting in this project not receiving a fire inspection. One project was not charged the New Single-Family fee resulting in $1,305.72 in lost revenue to the City.

OCA found several different types of fees were not accurately assessed over the testing period. Some of these errors resulted in overcharging customers but most errors resulted in undercharging customers.

SB 1473 – California Building Standards Administration Special Revolving Fund
OCA identified that SB1473 fees were inappropriately assessed to demolition permits issued by the City. Of the 13 demolition permits tested, 5 or 38% of Item 14
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2 the projects were incorrectly assessed the fee. The fee ranged from $1 to $41 across the projects sampled. In total, OCA estimated potential overcharges of less than $1,300 over the course of FY23 and FY24. While this represents a small amount in overcharged fees, charging unauthorized fees can have financial, legal, operational and reputational consequences and the City should take steps to minimize such occurrences.

Record Retention Fees
The City’s fee schedule requires that all projects with plans pay a records retention fee. In FY23, the fee was $7.04 per plan sheet and in FY24 $7.88 per plan sheet. This fee helps cover the City’s costs in maintaining such records.

Out of 60 sampled projects, OCA found that the City had not assessed record retention fees for 15 projects or 25% of sampled projects. For the 15 tested projects missing record retention fees, $184.41 in fees should have been assessed and collected but were not. This represents approximately $15,000 in uncollected record retention fees for FY23 and FY24 when applying this error rate to the entire population of permits.

Reinspection Fees
Built into the City’s fee structure is an initial and follow-up inspection.

Reinspection fees are assessed beginning with the second failed inspection in order to cover the cost of the third inspection, with additional fees required for each subsequent failure.

Only 84 re-inspection fees were charged in FY23 and FY24. In collaboration with PDS staff, OCA identified 164 permits during FY23 and FY24 out of 7,686 (approximately 2%) that might have missing re-inspection fees. OCA sampled 30 of the permits and found a total of 6 re-inspection fees that should have been charged but were not.

Factors contributing to inconsistent fee assessment
OCA identified three primary factors contributing to inconsistent fee assessment. First, OCA noted a general lack of internal controls and oversight of building permit and inspection assessments. Second, staff mentioned the complexity of the fee schedule and how the fees are organized in the City’s cloud-based building platform, Accela. Third, staff mentioned the lack of training available for new employees.

Refunds
All refunds evaluated were in alignment with the fee schedule, refunding 80% of the original fee amount unless there was a City error necessitating a full refund. However, out of the 10 refunds tested, 5 were missing finalized documentation showing that the refund was processed through accounting, a step that is specified in the department’s procedure. Staff should ensure that Item 14
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3 all final, accounting approved refund documents are included and saved in the appropriate records in Accela.

Recommendation We recommend the City:

1. Evaluate any areas identified by the audit where fees were inappropriately charged to customers and resolve any issues.

2. Reinstate periodic internal audits of building permit and reinspection fees on either a monthly or quarterly basis. This should include:
a. developing a documented quality control process with assigned responsibilities to ensure this activity is performed consistently moving forward,
b. procedures for providing feedback, and if appropriate, additional training to staff when errors are identified, and c. ongoing tracking and monitoring of issues to identify patterns or trends that might require wider training or corrective actions for the department.

1. Explore the feasibility of simplifying fees and improving the Accela platform by:
a. considering ways to simplify fee application processes and procedures including revisiting the fee structure itself and identifying opportunities to better communicate standards to customers,
b. automating certain fees such as SB1743 as an internal control and to help streamline the assessment process,
c. grouping fees by project type to ensure easier application by project coordinators, and
d. configuring the software to allow coordinators to select multiple fees at one time. Performing an assessment to determine the time it takes
for staff to individually select each permit versus
being able to select them in one step might help to establish how much time could be saved by this enhancement and
whether it is worth the investment. Such an assessment could also consider other fees for automation that are not specifically addressed through this audit.

3. We recommend the City evaluate the current training process and consider updating and/or reimplementing the onboarding and training program for new employees including comprehensive guidance on fee application, system use, as well as periodic, ongoing training.

4. Ensure staff retain all required documents when processing financial transactions such as permit fee refunds for greater transparency and accountability.

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4 Introduction

Objective

The objectives of this audit were to determine if the City’s building permit and inspection fees are accurately and consistently applied and evaluate the administration of the Development Services Program for adequate internal controls to safeguard the City from fraud, waste, and abuse.

Background The City’s Planning and Development Services Department (PDS) is responsible for administering building permits and inspection services for residential, commercial, and mixed-use development projects. These services ensure that all construction activities within city limits comply with applicable building codes, zoning ordinances, and health and safety regulations. Fees associated with these services such as building permit fees, and re-inspection fees, are intended to support the City’s cost-recovery efforts, maintain efficient service delivery, and ensure fairness and consistency in how applicants are charged.

Building permit and inspection fees are assessed on a cost-recovery basis within the development process and have a direct impact on residents, contractors, and businesses. The public expects these fees to be reasonable, consistently applied, and transparent. Inconsistencies or misapplications whether due to system limitations, staff discretion, or unclear guidance can lead to reputational risk, delays in construction timelines, or a perception of inequity among applicants.

In Palo Alto, the permit issuance and fee calculation process is managed through Accela, the City’s electronic permitting system. This system allows for the intake of permit applications, automated fee calculations, scheduling of inspections, and documentation of changes, waivers, and/or refunds. Accela plays a key role in enforcing standardized fee schedules and recording valuation data, but it also allows staff to manually override certain values under specific circumstances. This flexibility can introduce control risks if not adequately monitored.

During the audit period covering fiscal years 2023 through 2024, the City issued 7,686 building permits spanning residential remodels, new commercial construction, and other project types. The audit included a review of both plan check and inspection fee components, as well as related surcharges such as the SB 1473 state-mandated fee, technology fees, and record retention charges. In addition, the audit evaluated the processes and controls governing refunds, to ensure that all deviations from the standard fee schedule were properly documented, justified, and approved.

The intention of this audit is to provide independent assurance that the Development Services Program is functioning effectively and with appropriate internal controls.

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5 1 Government auditing standards require an external peer review at least once every three (3) years. The last peer review of the Palo Alto Office of the City Auditor was conducted in 2017. The Palo Alto City Council approved a contract with Baker Tilly U.S, LLP for internal audit services for October 2020 through June 2022 with an extension through June 2025. City Council appointed Kate Murdock, Audit Manager in Baker Tilly’s Risk Advisory practice, as City Auditor in May 2024. As a result of transitions in the Audit Office and peer review delays due to the COVID pandemic, an external peer review is targeted for 2025. It should be noted that Baker Tilly’s most recent firmwide peer review was completed in November 2024 with a rating of “Pass”. The scope of that peer review includes projects completed under government auditing standards. A report on the next firmwide peer review should be available later in 2024.

Scope The OCA obtained permit records from FY2023 to FY2024 and assessed permit activities and internal controls that manage the permit lifecycle across all applicable departments.

Methodology To achieve the audit objectives, the OCA performed the following procedures:
• Interviewed the appropriate individuals to gain an understanding of the organizational structure, processes, and controls related to building permit and inspection fees.
• Analyzed policies and procedures as well as the legislative and regulatory requirements to identify the criteria to be used for evaluation of control design and effectiveness.
• Conducted on-site walkthroughs to gain an understanding of the building permit process, from initial application through final inspection, to inform our assessment of internal controls and fee application. • Judgmentally selected a sample of 54 permits issued in FY23-24 for testing. The sample included the following permit types: Commercial Remodel or Addition, Demo, Minor, New Commercial Building, New Multi-Family, New Single Family, Residential Remodel or Addition, Use and Occupancy only, and other permits to determine if the City’s building permit and inspection fees are accurately and consistently applied. • Judgmentally selected a sample of 10 refunds for testing which were evaluated for supervisor approval, proper accounting, accuracy of the refund amount, and adequacy of supporting explanations. • Judgmentally selected a sample of Re-inspections for testing to determine if re-inspections were accurately and consistently applied in accordance with the City’s fee schedule and Palo Alto Municipal Code

16.04.110.
• Completed audit report of findings, conclusions, and recommendations based on the supporting evidence gathered.

Compliance
Statement
This audit activity was conducted from January 2025 to September 2025 in accordance with generally accepted government auditing standards, except for the requirement of an external peer review1. Those standards require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings, observations, and conclusions based on our audit objectives. We believe that the evidence obtained provides a reasonable Item 14
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6 basis for our findings, observations, and conclusions based on our audit objectives.

Organizational
Strengths
We noted the professionalism and responsiveness of the PDS throughout the audit. We appreciate the department’s participation in interviews, timely provision of building permit and inspection fee documentation for selected samples, and responsiveness to follow-up information requests.

The OCA greatly appreciates the support of the Development Services Program staff involved in conducting this audit activity.

Thank you!

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7 Detailed Analysis

Best Practices:

Building Permit
and Inspection
Fees Criteria
Municipalities are expected to administer building permit and inspection programs that are transparent, efficient, and cost-effective. Leading practices endorsed by the Government Finance Officers Association (GFOA), International Code Council (ICC), California Building Officials (CALBO), and peer cities across the region support consistent fee application, sound internal controls, and public accountability. Benchmarking fee structures, processes, and outcomes against similar jurisdictions is a critical part of evaluating whether a city’s practices remain aligned with both regulatory and public service expectations.

Key Best Practices Include:

Fee Schedule Transparency and Accessibility
Cities should maintain a clearly defined, publicly accessible fee schedule that is easy to interpret and reviewed at regular intervals ideally on an annual or biennial basis to ensure alignment with cost-of-service goals and regulatory changes. Palo Alto’s current fee schedule is easily accessible to the public and outlines multiple fee categories, including plan check fees, inspection fees, and state-mandated assessments such as SB 1473.

Use of ICC Valuation Tables and Cost of Services Study
Peer cities including Mountain View, Sunnyvale, and San Jose utilize the International Code Council’s (ICC) Building Valuation Data as a standardized basis for estimating construction costs, which informs the calculation of plan review and inspection fees. Industry best practices recommend updating these valuation tables annually and applying them consistently across all permit types. Palo Alto annually updated valuation tables aligning with industry best practices until FY2026.

Since the timeframe of the audit, the Planning and Development Services Department has completed and implemented a cost of services study and developed an alternative fee methodology after determining the ICC valuation tables were too complex to accurately apply to commercial construction projects.

The new hybrid model uses square footage for residential fees and an expanded valuation tier system for commercial projects, creating a more equitable structure that more accurately reflects project complexity and the associated costs of plan review and inspection services. This update also aligns with industry best practices of updating fees through a cost of services study every five to eight years.

Benchmarking Against Peer Jurisdictions
Benchmarking against peer cities helps assess whether Palo Alto’s fees are competitively positioned and cost-recovery goals are reasonable. For example, plan check fees for typical residential remodels in Palo Alto were found to be within 5– 15% of those charged by Mountain View and Sunnyvale. Inspection fees per permit were slightly higher than those in San Jose.

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8 2 Significant changes were made to the Palo Alto FY2026 Fee Schedule and some of the benchmarked fees above may no longer apply.

Table 1: FY2024 Development Services Fees Benchmarked2
= Fee/fee structure similar to Palo Alto
= Fee/fee structure differs from Palo Alto

Fee Category Palo Alto Mountain View Sunnyvale San Jose Plan Check Fee
• Based on ICC
valuation
• Sliding scale of
permit fee
• Based on ICC
valuation
• ~70% of permit
fee
• Based on ICC
valuation
• 65–75% of permit
fee
• Based on ICC
valuation
• Sliding scale of
permit fee
Building Permit
Fee
• Based on ICC
• Tiered structure
as project value
increases
• Based on ICC

• Based on ICC

• Based on ICC
• Residential
adjusted lower

Inspection Fee
• Typically
included in
permit fee
• Typically
included in
permit fee
• Separate line
item, based on
inspection hours
• Flat fee for
typical
inspections
Technology
Surcharge
• Incorporated into
the fee schedule
• 4–6% surcharge
applied to all
permits
• 5% surcharge
with cap

• 3% surcharge
• Waived for low-
income or ADA
retrofits
SB 1473 Fee • Charged per CA
BSC standard
• Charged per CA
BSC standard
• Charged per CA
BSC standard
• Charged per CA
BSC standard
• Auto calculated
in system
Record
Retention Fee
• FY24 $7.56 Per
Plan Sheet
• Flat rate ($5–
$20)
• Often bundled
into tech
surcharge
• Sometimes
included in admin
fee
Permit Valuation
Basis
• ICC tables
• Exceptions with
approval
• ICC tables
• Exceptions with
approval
• ICC tables
• Exceptions with
approval
• ICC tables
• Exceptions with
approval
Refund Policy
• Standard form &
supervisor
approval required
• Standard form &
supervisor
approval required
• Standard form &
supervisor
approval required
• Standard form &
supervisor
approval required
• Online request
system
Public Fee
Calculator Not available Not available Not available
• Yes, robust
estimator with
plan set details

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9 3 https://statescoop.com/san-jose-ai-permitting/
4 https://sunnyvaleca.legistar.com/LegislationDetail.aspx?FullText=1&G=FA76FAAA-7A&GUID=8BB4D40E- 185A-4BC3-B6EA-9CC97BE43861&ID=7419969&Options=&Search= 5 https://developmentpermits.mountainview.gov/about-permits/fees/planning-permit-fees/planning-cost-recovery- fees
6 https://permits.sanjoseca.gov/fee-estimator/building
Automated Fee Enforcement Through Permit Systems
Accela and other e-permitting systems should be configured to calculate fees automatically based on input valuation and permit type. Manual overrides should be limited to authorized personnel and logged with justification and supervisory approval. Some peer cities, such as San Jose, have implemented audit flags within their permitting software3 to detect inconsistencies in valuation entries or fee waivers.

Standardized Refund and Adjustment Workflows
Cities should have formal, written policies for granting refunds or fee adjustments, with clear documentation standards. Benchmark cities typically require a refund request form, written justification, and supervisor sign-off before processing. In contrast, inconsistent practices can lead to errors or public perception of favoritism.

The City of Palo Alto currently follows the practices of benchmark cities.

Peer Comparison of Staffing and Cost Recovery
Cities like Sunnyvale4 and Mountain View5 regularly assess whether their Development Services programs are meeting cost-recovery targets and whether staffing levels align with workload demands. Palo Alto conducts similar assessments through its annual fee review and budget process. These evaluations are used to inform fee increases or process improvements.

Public-Facing Permit Calculators and Estimators
To improve transparency and reduce disputes, San Jose offers an online permit fee estimator

6. This tool allows applicants to enter basic project information and receive a preliminary estimate of fees owed enhancing trust and reducing back-and-forth with staff.

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10 Audit Results
Finding 1:

Overall, fee
assessments for
most major fees
were accurately
assessed, but
some smaller
fees were not
applied
consistently
across all
transactions.

As discussed in the Background section of this report, the City’s Planning and Development Services Department (PDS) provides building permit and inspection services for residential, commercial and mixed-use building projects. The City’s Municipal Fee Schedule establishes the annual fees that will be charged for these services.

The PDS is responsible for ensuring these fees are accurately and consistently applied. Building permit applications are typically submitted through the City’s online platform, Accela. Project coordinators review applications and determine which fees should be assessed based on the scope of the work being performed.

OCA tested a sample of building permit types and inspection fees for accuracy and consistency.

In FY23 and FY24, there were a total of 4,774 projects reviewed by the Development Services Center and 7,686 building permits issued. The Development Services Center collected approximately $15 million in revenue in FY23 and $17 million in revenue in FY24.

Most major fees were accurately assessed, but some smaller fees were not consistently applied.

OCA sampled 60 building permits from several different project types including: Commercial Remodel or Addition, Demolition, New Commercial Building, New Multi-Family, New Single Family, Residential Remodel or Addition, Use and Occupancy, and Minor.

OCA judgmentally selected projects that had similar descriptions in order to determine if the same types of projects were assessed the same fees. While most major fees were accurately assessed, OCA found several smaller fees were not consistently applied. Some of these errors resulted in overcharging customers but most errors resulted in undercharging customers.

Building Permit Fees
Aside from SB1473 and Record Retention fee errors, OCA
identified 2 projects out of 60 or 3% with missing fees. For one “Minor” building project, PDS staff confirmed that the project was not assessed a fire plan check fee. As a result, it appears this project did not receive a fire inspection. OCA found one error in the “New Single Family” home projects we evaluated. This project was not assessed the “New Single Family” fee of $1,305.72 as listed in the FY24 Fee Schedule. Staff confirmed that this was in error , and
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11 could not provide an accurate estimate of uncollected building permit fees.

SB 1473 – California Building Standards Administration Special Revolving Fund
SB 1473 took effect in January 2009 and was established as a surcharge on both residential and non-residential building permits by the California Building Standards Commission. This surcharge fee has a rate of four dollars ($4) per one hundred thousand ($100,000) building valuation and is applied in increments of $25,000 with $1 being the minimum fee charged. The state requires that fees are submitted quarterly to the California Building Standards Commission. The bill also provides that a city may retain up to ten percent of the collected fees for administrative costs and code enforcement education.

The PDS management confirmed that SB1473 fees are only applied to building permits and do not apply to standalone permits such as electrical, fire, or demolition. OCA’s testing found that some demolition permits were wrongly assessed the SB1473 fee. In FY23 and FY24 there were 224 demolition permits issued. OCA tested a sample of 13 permits. Out of the 13 demolition permits sampled, OCA found that 5 of the 13 or 38% had been charged the fee. On these permits, the SB1473 permit fee ranged from $1 to $41 with an average fee charge of $14.80 . If this error rate was found in the larger population of demolition permits, potentially 86 permits were erroneously charged the fee. Using the average amount of over- assessed fees, the City may have overcharged approximately $1,272.80. While this represents a small amount in overcharged fees, charging unauthorized fees can have financial, legal, operational and reputational consequences and the City should take steps to minimize such occurrences.

Out of 60 samples, OCA found that the City had not assessed record retention fees for 15 projects or 25% of sampled projects.

For the 15 projects where record retention fees were not assessed, $184.41 in fees (an average of $12.29 per project) should have been assessed and collected but were not. If we assume an error rate of 25% for the entire population of 4,774 projects in FY23 and FY24, 1,194 projects may not have been correctly assessed record retention fees. Using the average record retention fees collected on Item 14
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12 the projects OCA sampled, OCA estimates the City may have underassessed $14,674.26 in record retention fees. While this represents less than a tenth of a percent of the total revenue collected by the Development Center each year, it is important to ensure fees are consistently and fairly assessed. OCA did note that based on the updated FY2026 fee model, record retention costs have been incorporated into the technology costs and therefore, the City no longer collects a separate record retention fee.

Reinspection Fees
Built into the City’s fee structure for residential projects are initial and follow-up inspections. Reinspection fees are assessed beginning with the second failed inspection in order to cover the cost of the third inspection, with additional fees required for each subsequent failure. Re-inspection fees not only cover the additional cost of the work performed by the City but also serve to disincentivize the customer from using City services in a way not intended. While these fees are an important tool for the Program to ensure efficient and timely review, it is important to note that there is flexibility in how they are applied and staff judgement in applying these fees is key to their administration. These fees do not apply to commercial and multi-family construction projects which have re- inspection fees built into the permit fees.

Based on reports provided by staff, OCA found the City only charged 84 reinspection fees during FY23 and FY24. OCA sampled 10 of these projects where re-inspection fees were charged to see if the fees had been applied accurately and found no errors.

In collaboration with PDS staff, OCA identified 164 permits during FY23 and FY24 out of 7,686 (approximately 2%) that might have missing re-inspection fees. OCA sampled 30 of these permits and found a total of 6 re-inspection fees that should have been charged but were not. It is difficult to put these numbers in context given that each permit is different and might have a different likelihood of needing a reinspection. However, assuming that for every 30 permits, one would find 6 re-inspections that were not charged a fee, this results in a rate of 1 re-inspection per every 5 permits.

Assuming a population of 164 permits (as noted above), this results in potentially 33 re-inspection fees that were not collected during FY23 and FY24. In the FY2023 Fee Schedule, each “primary” re- inspection costs $172.95 and each “secondary” re-inspection costs $93.03. Assuming FY23 fees, at the low end, this represents approximately $3,070 in uncollected fees and at the high end approximately $5,707.

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13 inspection and a fee should be applied. PDS management agreed that additional guidance would help ensure that these fees are more consistently and accurately applied. When a customer is informed of issues at the initial inspection, it is up to the customer to identify if they need additional resources to work to fix the problem and ensure they meet building codes. Re-inspections result in additional use of staff time and the more re-inspections the City is forced to perform, the more staff time is consumed with less available time to move other projects forward. Failing to apply fees consistently can present financial, legal and operational risks including lost revenue and possible exposure to lawsuits due to unfair treatment.

Factors contributing to inconsistent fee assessment
Through interviews with staff in PDS and observations of the building permit and inspection processes, OCA identified three primary factors contributing to inconsistent fee assessment. First, OCA noted a general lack of internal controls and oversight of building permit and inspection assessments. Second, staff mentioned the complexity of the fee schedule and how the fees are organized in the City’s cloud-based building platform, Accela. Third, staff mentioned the lack of training available for new employees.

Lack of Oversight and Internal Controls
According to PDS management and staff, the City discontinued regular internal audits of building permit and inspection fees during the COVID-19 pandemic and has not been able to resume these checks. According to management, this function was previously supported by the Development Center Manager and following the pandemic, the position’s priorities were realigned to focus on customer service initiatives. These efforts included expanding appointment availability to accommodate walk-in, virtual, and in- person customers. Additionally, management reported that the manger’s oversight was expanded to include both project coordination and planning staff located at the Development Center to enhance customer service and technical expertise at the counter.

OCA noted that the Accela system has the capability to flag projects at random or to flag projects based on defined criteria established by the user agency. For example, San Jose reports that they have configured the system to flag projects with inconsistent valuations and when fees are waived.

Staff also indicated that while they can consult with other project coordinators, the Development Center Manager, and the Chief Building Official on permitting questions, there is no formal, regular review of individuals’ work. According to management, the Item 14
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14 Development Center Manager provides ongoing informal training, which includes discussion on application processing questions form the project coordinators. In addition, these meetings occasionally include guest speakers from other partner departments to expand permitting knowledge during weekly program meetings.

Without periodic review of staff work and building permit and inspection fee assessments, management is unable to determine if fees are being consistently and accurately assessed and misses the opportunity to correct staff errors early, making it more likely that mistakes are carried forward into future fee assessments.

Complexity of the Fee Schedule and Accela Configuration According to PDS management, the City’s fee schedule has multiple components, and its application varies based on the specific requirements of each project. The schedule includes more than 18 different fee categories (e.g., Building Permit, Construction & Demolition, Electrical, Green Building, etc.) Within each fee category, there are numerous different fees that might apply to a project. The complexity of the fee schedule reflects the complexity of construction process itself. There are thousands of building projects constructed in Palo Alto each year and even two projects that may seem similar – for example, two new single-family homes, there will be many unique aspects of each project such as solar panels, a pool, a garage, etc.

While the fee schedule was recently updated with a cost of services study, staff indicated that although some areas such as the residential square footage model were simplified, the schedule and process for assessing fees remains complex making it difficult to ensure consistency. In addition, staff concurred that developing standard operating procedures for fee applications will provide more transparency fo
r customers and reduce potential frustrations. Future
fee studies should explore ways to further simplify the schedule and alternate methods for communicating standards and requirements to customers, such as through a public facing fee calculator.

Accela is designed to streamline and automate building application, permitting and inspection processes and the platform is used by many cities and counties in California. While staff indicated there are many positive aspects to the City’s use of the platform, one area that is challenging is how fees are configured in the system.

Currently, fees are not grouped by project category and staff are forced to scroll through the entire system to locate fees. Many building projects that come through the City’s Development Services Center are complex and require multiple fee assessments.

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15 multiple screens and scroll down various permit lists to locate the appropriate fee and then repeat this process for each new fee. Staff stated that if fees were grouped, with a list of fees that are typically assessed for that type of project, it would save on time and also help with consistency as users would have a list to choose from rather than having to remember and look up each individual fee that might apply. In addition, staff stated that if the system could be configured to allow the project coordinator to select multiple fees at one time that would also save time rather than having to open the list for each fee selection.

OCA spoke with the PDS Accela technical expert, and it appears that some, if not all, of the changes above could be implemented with support. The City contracts with a vendor that specializes in Accela configurations when changes need to be made to the system. The City will need to determine if the cost of making these changes is feasible.

OCA also noted that some fees could be automated in the system.

For example, record retention fees should be charged on every project. If there were a field prompting project coordinators to enter the number of plan pages when entering other essential project information, the system could automatically calculate this per page fee and not require any additional steps. In addition, the SB1473 fee applies to certain types of projects and could be automatically added to these project types.

Training
Staff reported that they attend training twice a year through CALBO, the California Building Officials. However, staff also reported that there isn’t a formal training process for new hires. According to staff, the City had a more formalized onboarding and training program for new project coordinators prior to the Covid 19 pandemic. According to management, changes to processes and procedures driven by new system requirements for application processing necessitated updates to formal training materials and standard operating procedures following the pandemic. Management asserted that development of these updated procedures and training programs is needed to align with current practices.

Currently, new project coordinators are primarily trained by shadowing another project coordinator, however there are some downsides staff noted to this approach. The coordinator being shadowed may not be assigned the breadth of different project types during the shadow period leaving gaps in knowledge for the new individual. The coordinator is providing training in the moment but also tasked with performing their primary job function and shared information may not be complete or provide the full context Item 14
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16 for decisions being made. Staff indicated a more formal and dedicated training program would be helpful.

According to the ICC Code of Ethics, code professionals have a duty to maintain and improve their competence. ICC training standards reinforce that jurisdictions should ensure staff are properly trained and supported to administer building codes and related fee structures. Sufficient, ongoing training can help minimize the risk of errors, inconsistent application of fees and strengthen compliance with building codes.

Additional areas for improvement
As part of this audit, OCA also evaluated the refund process. In FY23 and FY24 there were a total of 107 refunds issued. OCA randomly selected refunds for testing, as well as judgmentally selecting a few of the larger refunds. Refunds were tested for evidence of supervisor/manager approval, to ensure the amount aligns with the refund receipt and was appropriately processed through accounting, and that the amount refunded was in alignment with the fee schedule. All refunds evaluated were in alignment with the fee schedule, refunding 80% of the original fee amount unless there was a City error necessitating a full refund. However, out of the 10 refunds tested, 5 lacked the required documentation as outlined in the department procedure, which requires uploading the final refund documentation signed by a Senior Management Analyst. In these cases, staff had uploaded the refund documents initially sent to Accounting, but did not replace them with the finalized, signed versions once processing was complete. Staff should ensure that all final refund documents are included and saved in the appropriate files in Accela

Recommendation We recommend the City:

1. Evaluate any areas identified by the audit where fees were inappropriately charged to customers and resolve any
issues.

2. Reinstate periodic internal audits of building permit and reinspection fees on either a monthly or quarterly basis. This should include:
a. developing a documented quality control process
with assigned responsibilities to ensure this activity is performed consistently moving forward,
b. procedures for providing feedback, and if
appropriate, additional training to staff when errors
are identified, and
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17 c. ongoing tracking and monitoring of issues to identify patterns or trends that might require wider training or corrective actions for the department.

3. Explore the feasibility of simplifying fees and improving the Accela platform by:
a. considering ways to simplify fee application
processes and procedures including revisiting the fee
structure itself and identifying opportunities to better communicate standards to customers,
b. automating certain fees such as SB1743 as an
internal control and to help streamline the
assessment process,
c. grouping fees by project type to ensure easier
application by project coordinators, and
d. configuring the software to allow coordinators to
select multiple fees at one time. Performing an
assessment to determine the time it takes for staff to
individually select each permit versus being able to
select them in one step might help to establish how
much time could be saved by this enhancement and
whether it is worth the investment. Such an
assessment could also consider other fees for
automation that are not specifically addressed
through this audit.

4. We recommend the City evaluate the current training
process and consider updating and/or reimplementing the onboarding and training program for new employees
including comprehensive guidance on fee application,
system use, as well as periodic, ongoing training.

5. Ensure staff retain all required documents when processing financial transactions such as permit fee refunds for greater transparency and accountability.

Management
Response
Responsible Department(s): Planning & Development Services Concurrence: Agree
Target Date: 4th Quarter Fiscal Year 2026
Action Plan:

1. PDS is reviewing appropriate actions to address the areas identified by the audit where fees were inappropriately charged and will implement remediating actions as appropriate. (Target Date: Q2 FY 2026)

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18 2. PDS will develop a documented quality control process to ensure that periodic internal audits of building permit and reinspection fees take place. This will include exploring technical solutions with Accela to flag permits for review as well as quarterly review of a randomized sample of permits.

Concurrently, PDS will provide feedback and additional training when errors are identified and will also longitudinally track errors to identify trends and patterns. (Target Date: Q4 FY 2026)

3. PDS will explore the following via a request for proposals (RFP) for the Permitting and Land Use Management system:
a. standard operating procedures for fee application by project type;
b. providing clear guidance to applicants on how to
calculate project valuations to create further equity in fee application;
c. conducting additional analysis with a fee consultant to refine how fees are applied to projects with multiple
standalone components, such as exploring the use of a
fee multiplier;
d. adding a permit fee estimation tool for simple projects to help applicants better understand permitting fees and
project costs early in the process, increasing
transparency and accountability in staff application of fees; and
e. Assess tradeoffs of implementing technical solutions within Accela and feasibility of those enhancements to
enhance the internal controls of the platform, including automating certain fees, grouping other fees, and
configuring the software to better reflect the standard ‘use cases’ by project coordinators to minimize errors.

4. Staff agree an assessment of the current process and development of a onboarding and training program for staff including updating standard operating procedures for fee application by permit type and system navigation. (Target Date:

Q4 FY 2026)

5. PDS staff will review existing refund procedures with administrative staff and retain all required final documents when processing financial transactions. Currently, all refunds are processed through accounting and have the proper
documentation and signature approvals. Accela records should also be updated to maintain final signed copies rather than drafts. Additionally, staff will seek to consolidate refund transactions and establish a process to periodically audit refunds; regular review of transactions such as refunds will enhance compliance and internal controls. (Target Date: Q4 FY 2026)

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13 PROFESSIONAL SERVICES TASK ORDER
TASK ORDER FY25-4.31 Junior Museum and Zoo
Consultant shall perform the Services detailed below in accordance with all the terms and conditions of the Agreement referenced in Item 1A below. All exhibits referenced in Item 8 below are incorporated into this Task Order by this reference. The Consultant shall furnish the necessary facilities, professional, technical and supporting personnel required by this Task Order as described below.

CONTRACT NO. C21179340A
OR PURCHASE ORDER REQUISITION NO. (AS APPLICABLE)
1A. MASTER AGREEMENT NO. (MAY BE SAME AS CONTRACT / P.O. NO. ABOVE): C21179340A 1B. TASK ORDER NO.: FY25-4.31

2. CONSULTANT NAME: Baker Tilly Advisory Group, LP

3. PERIOD OF PERFORMANCE: START: January 1, 2025 COMPLETION: June 30, 2025

4. TOTAL TASK ORDER PRICE: $89,900

BALANCE REMAINING IN MASTER AGREEMENT/CONTRACT TBD

5. BUDGET CODE_______________ COST CENTER________________ COST ELEMENT______________ WBS/CIP__________ PHASE__________

6. CITY PROJECT MANAGER’S NAME & DEPARTMENT:

Lydia Kou, Chair of the City Council’s Policy and Services Committee

7. DESCRIPTION OF SCOPE OF SERVICES (Attachment A)
MUST INCLUDE:
 SERVICES AND DELIVERABLES TO BE PROVIDED
 SCHEDULE OF PERFORMANCE
 MAXIMUM COMPENSATION AMOUNT AND RATE SCHEDULE (as applicable)  REIMBURSABLE EXPENSES, if any (with “not to exceed” amount)

8. ATTACHMENTS: A: Task Order Scope of Services B (if any): N/A I hereby authorize the performance of the work
described in this Task Order.

APPROVED:

CITY OF PALO ALTO
BY:____________________________________
Name __________________________________
Title___________________________________
Date ___________________________________
I hereby acknowledge receipt and acceptance of
this Task Order and warrant that I have authority
to sign on behalf of Consultant.

APPROVED:

COMPANY NAME: Baker Tilly Advisory Group,
LP
BY:____________________________________
Name __________________________________
Title___________________________________
Date ___________________________________
Docusign Envelope ID: F60E09CC-400F-404E-8132-93318BE5ADE6 Kate Murdock
Manager/ City Auditor
12/23/2024
Council Member
Council Member Lydia Kou
12/25/2024
April 30, 2026
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14 Attachment A

DESCRIPTION OF SCOPE OF SERVICES
Introduction
Attachment A, the Description of Scope of Services, contains the following four (4) elements:
 Services and Deliverables To Be Provided
 Schedule of Performance
 Maximum Compensation Amount and Rate Schedule (As Applicable)  Reimbursable Expenses, if any (With “Not To Exceed” Amount) Services & Deliverables
Baker Tilly’s approach to conducting an internal audit of the Junior Museum and Zoo involves three (3) primary steps:
 Step 1: Audit Planning
 Step 2: Fieldwork and Testing
 Step 3: Reporting
Step 1 – Audit Planning
This step consists of the tasks performed to adequately plan the work necessary to address the overall audit objective and to solidify mutual understanding of the audit scope, objectives, audit process, and timing between stakeholders and auditors. Tasks include:
 Gather information to understand the environment under review o Understand the environment under assessment
o Assess the City code, regulations, and other standards and expectations o Assess prior audit results, as applicable
o Assess additional documentation and conduct interviews as necessary  Assess the audit risk
 Prepare an audit planning memo and audit program
o Refine audit objectives and scope
o Identify the audit procedures to be performed and the evidence to be obtained and examined  Announce the initiation of the audit and kick-off meeting with key stakeholders o Discuss audit objectives, scope, audit process, timing, resources, and expectations o Discuss documentation and interview requests for the audit Step 2 – Fieldwork and Testing
The step involves executing the procedures in the audit program to gather information, interview individuals, and analyze the data and information to obtain sufficient evidence to address the audit objectives The preliminary audit objective is to determine if the City’s Junior Museum and Zoo is operating effectively and efficiently to fulfill the program’s mission. Procedures include, but are not limited to:
 Interviewing the appropriate individuals to gain an understanding of the organizational structure, processes, and controls related to the Junior Museum and Zoo  Analyze policies and procedures as well as the program mission and objectives to identify the criteria to be used for evaluation of control design and effectiveness  Compare processes and controls against best practices Docusign Envelope ID: F60E09CC-400F-404E-8132-93318BE5ADE6 Item 14
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15 Step 3 – Reporting
In Step 3, the project team will perform tasks necessary to finalize audit working papers, prepare and review a draft report with stakeholders, and submit a final report for management response. Tasks include:
 Developing findings, conclusions, and recommendations based on the supporting evidence gathered
 Validating findings with appropriate individuals and discuss the root cause of the identified findings
 Complete supervisory review of working papers and a draft audit report  Distribute a draft audit report and conduct a closing meeting with key stakeholders o Discuss the audit results, findings, conclusions, and recommendations o Discuss management responses
 Obtain written management responses and finalize a report  Review report with members of City Council and/or the appropriate Council Committee Deliverables:

The following deliverables will be prepared as part of this engagement:
 Audit Report
 Policy & Services Committee Audit Report Presentation Schedule of Performance
Anticipated Start Date: January 1, 2025
Anticipated End Date: June 30, 2025
Maximum Compensation Amount and Rate Schedule
The not-to-exceed maximum, inclusive of reimbursable expenses (as summarized below) for this Task is $89,900.

The not-to-exceed budget is based on an estimate of 500 total project hours, of which a minimum of 40 are estimated to be completed by the City Auditor.

Reimbursable Expenses
We plan to complete all work remote including all interviews and documentation review. However, during the planning and fieldwork phases of this audit, the City and Baker Tilly may mutually determine it will be beneficial to perform a portion of the work on-site. Given this possibility, Baker Tilly could incur expenses for this Task.

The not-to-exceed maximum for reimbursable expenses for this Task is $6,500.

The following summarizes anticipated reimbursable expenses:
 Round-trip Airfare – $2,000 (1 round trip flight x 2 auditors)  Ground transportation – $800 (car rental or Uber/taxi)  Hotel accommodation – $3,000 (2 rooms x 4 nights)
 Food & Incidentals – $2,100
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19 PROFESSIONAL SERVICES TASK ORDER
TASK ORDER FY25-4.33 Public Safety Staffing
Consultant shall perform the Services detailed below in accordance with all the terms and conditions of the Agreement referenced in Item 1A below. All exhibits referenced in Item 8 below are incorporated into this Task Order by this reference. The Consultant shall furnish the necessary facilities, professional, technical and supporting personnel required by this Task Order as described below.

CONTRACT NO. C21179340A
OR PURCHASE ORDER REQUISITION NO. (AS APPLICABLE)
1A. MASTER AGREEMENT NO. (MAY BE SAME AS CONTRACT / P.O. NO. ABOVE): C21179340A 1B. TASK ORDER NO.: FY25-4.33

2. CONSULTANT NAME: Baker Tilly Advisory Group, LP

3. PERIOD OF PERFORMANCE: START: January 1, 2025 COMPLETION: June 30, 2025

4. TOTAL TASK ORDER PRICE: $95,670

BALANCE REMAINING IN MASTER AGREEMENT/CONTRACT TBD

5. BUDGET CODE_______________ COST CENTER________________ COST ELEMENT______________ WBS/CIP__________ PHASE__________

6. CITY PROJECT MANAGER’S NAME & DEPARTMENT:

Lydia Kou, Chair of the City Council’s Policy and Services Committee

8. ATTACHMENTS: A: Task Order Scope of Services B (if any): N/A I hereby authorize the performance of the work
described in this Task Order.

APPROVED:

COMPANY NAME: Baker Tilly Advisory Group,
LP
BY:____________________________________
Name __________________________________
Title___________________________________
Date ___________________________________
Docusign Envelope ID: F60E09CC-400F-404E-8132-93318BE5ADE6 Manager/ City Auditor
Kate Murdock
12/23/2024
Council Member
Council Member Lydia Kou
12/25/2024
April 30, 2026
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20 Attachment A

DESCRIPTION OF SCOPE OF SERVICES
Introduction
Attachment A, the Description of Scope of Services, contains the following four (4) elements:
 Services and Deliverables To Be Provided
 Schedule of Performance
 Maximum Compensation Amount and Rate Schedule (As Applicable)  Reimbursable Expenses, if any (With “Not To Exceed” Amount) Services & Deliverables
Baker Tilly’s approach to conducting an internal audit of Public Safety Staffing including Overtime three (3) primary steps:
 Step 1: Audit Planning
 Step 2: Fieldwork and Testing
 Step 3: Reporting
Step 1 – Audit Planning
This step consists of the tasks performed to adequately plan the work necessary to address the overall audit objective and to solidify mutual understanding of the audit scope, objectives, audit process, and timing between stakeholders and auditors. Tasks include:
 Gather information to understand the environment under review o Understand the environment under assessment
o Assess the City code, regulations, and other standards and expectations o Assess prior audit results, as applicable
o Assess additional documentation and conduct interviews as necessary  Assess the audit risk
 Prepare an audit planning memo and audit program
o Refine audit objectives and scope
o Identify the audit procedures to be performed and the evidence to be obtained and examined  Announce the initiation of the audit and kick-off meeting with key stakeholders o Discuss audit objectives, scope, audit process, timing, resources, and expectations o Discuss documentation and interview requests for the audit Step 2 – Fieldwork and Testing
The step involves executing the procedures in the audit program to gather information, interview individuals, and analyze the data and information to obtain sufficient evidence to address the audit objectives The preliminary audit objective is to determine if the Public Safety Departments (Fire and Police) are effectively and efficiently staffed including use of overtime:
 Interviewing the appropriate individuals to gain an understanding of the organizational structures, processes, and controls related to staffing and use of overtime including plans and systems used  Analyze policies and procedures related to Public Safety staffing to identify the criteria to be used for evaluation of control design and effectiveness
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21  Analyze Public Safety performance metrics to determine if staffing levels enable desired performance outcomes
 Compare performance processes and controls against best practices Step 3 – Reporting
In Step 3, the project team will perform tasks necessary to finalize audit working papers, prepare and review a draft report with stakeholders, and submit a final report for management response. Tasks include:
 Developing findings, conclusions, and recommendations based on the supporting evidence gathered
 Validating findings with appropriate individuals and discuss the root cause of the identified findings
 Complete supervisory review of working papers and a draft audit report  Distribute a draft audit report and conduct a closing meeting with key stakeholders o Discuss the audit results, findings, conclusions, and recommendations o Discuss management responses
 Obtain written management responses and finalize a report  Review report with members of City Council and/or the appropriate Council Committee Deliverables:

The not-to-exceed budget is based on an estimate of 500 total project hours, of which a minimum of 50 are estimated to be completed by the City Auditor.

The not-to-exceed maximum for reimbursable expenses for this Task is $6,500.

The following summarizes anticipated reimbursable expenses:
• Round-trip Airfare – $2,000 (1 round trip flight x 2 auditors) • Ground transportation – $800 (car rental or Uber/taxi) • Hotel accommodation – $3,000 (2 rooms x 4 nights)
• Food & Incidentals – $2,100
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22 PROFESSIONAL SERVICES TASK ORDER
TASK ORDER FY25-4.34 Follow-Up Audit Activities
Consultant shall perform the Services detailed below in accordance with all the terms and conditions of the Agreement referenced in Item 1A below. All exhibits referenced in Item 8 below are incorporated into this Task Order by this reference. The Consultant shall furnish the necessary facilities, professional, technical and supporting personnel required by this Task Order as described below.

CONTRACT NO. C21179340A
OR PURCHASE ORDER REQUISITION NO. (AS APPLICABLE)
1A. MASTER AGREEMENT NO. (MAY BE SAME AS CONTRACT / P.O. NO. ABOVE): C21179340A 1B. TASK ORDER NO.: FY25-4.34

2. CONSULTANT NAME: Baker Tilly Advisory Group, LP

3. PERIOD OF PERFORMANCE: START: January 1, 2025 COMPLETION: June 30, 2025

4. TOTAL TASK ORDER PRICE: $59,390

BALANCE REMAINING IN MASTER AGREEMENT/CONTRACT TBD

5. BUDGET CODE_______________ COST CENTER________________ COST ELEMENT______________ WBS/CIP__________ PHASE__________

6. CITY PROJECT MANAGER’S NAME & DEPARTMENT:

Lydia Kou, Chair of the City Council’s Policy and Services Committee

8. ATTACHMENTS: A: Task Order Scope of Services B (if any): N/A I hereby authorize the performance of the work
described in this Task Order.

APPROVED:

COMPANY NAME: Baker Tilly Advisory Group,
LP
BY:____________________________________
Name __________________________________
Title___________________________________
Date ___________________________________
Docusign Envelope ID: F60E09CC-400F-404E-8132-93318BE5ADE6 Kate Murdock
Manager/ City Auditor
12/23/2024
Council Member
12/25/2024
Council Member Lydia Kou
April 30, 2026
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23 Attachment A

The following deliverables will be prepared as part of this engagement:
 Annual Status of Audit Recommendations Report
 Policy & Services Committee Report Presentation
Schedule of Performance
Anticipated Start Date: January 1, 2025
Anticipated End Date: June 30, 2025
Maximum Compensation Amount and Rate Schedule
The not-to-exceed maximum, inclusive of reimbursable expenses (as summarized below) for this Task is $59,390.

The not-to-exceed budget is based on an estimate of 500 total project hours, of which a minimum of 40 are estimated to be completed by the City Auditor.

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City Council
Staff Report
From: City Manager
Report Type: ACTION ITEMS
Lead Department: Planning and Development Services
Meeting Date: December 8, 2025
Report #:2511-5569
TITLE
REINTRODUCED FIRST READING: Adoption of an Ordinance Updating Palo Alto Municipal Code (PAMC) Section 18.40.250 (Lighting) of Chapter 18.40 (General Standards and Exceptions) and Amending Chapters 18.10, 18.12, 18.28, and Section 18.40.230 of Title 18 (Zoning) to Adopt New Outdoor Lighting Regulations; CEQA Status — Exempt pursuant to CEQA Guidelines Section 15308 (Actions for Protection of the Environment)

RECOMMENDATION
Staff recommend the City Council adopt the Draft Ordinance updating Palo Alto Municipal Code (PAMC) Section 18.40.250 (Lighting) of Chapter 18.40 (General Standards and Exceptions) and Amending Chapters 18.10, 18.12, 18.28, and Section 18.40.230 of Title 18 (Zoning) to adopt new outdoor lighting regulations.

EXECUTIVE SUMMARY
Note: This report has been updated from its initial November 10, 2025, publication to incorporate a recent ordinance change that expressly exempts select public facilities, as discussed in the analysis section.

The draft Lighting Ordinance (Attachment A) implements part of one of the City Council’s priorities (No. 18, Council consideration of an ordinance implementing Bird Safe Glass & Wildlife Light Pollution Protections standards) and is consistent with Comprehensive Plan policies (including Policies N-1.9, N-3.3, and N-7.5). The draft ordinance, which has been modified based on City Council direction on April 7, 2025, aims to reduce light pollution and align with Dark Sky principles in order to increase the health and well-being of Palo Alto residents, protect wildlife and natural ecosystems, and reduce light pollution. The City Council’s direction at the April hearing aligned with the Planning and Transportation Commission (PTC) recommendations from October 2024, including requiring that new standards apply to replacement of existing lighting; allowing additional exceptions; and increasing efforts to raise awareness, which may help reduce the number of complaints and reliance on code Item 15
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enforcement. In addition, the City Council requested that requirements be included for already- installed existing lighting to comply with the new lighting standards after a set time period.

The City does not have sufficient resources to proactively enforce the ordinance; staff will respond to egregious violations as capacity allows and will rely on outreach and community- based compliance measures to support implementation.

BACKGROUND
Early this year, Council identified 2025 City Council Priorities and Objectives. Under the Climate Action & Adaptation, and Natural Environment (CA) category, the City Council directed staff to prepare an ordinance implementing wildlife light pollution protections standards (2025 Council Priority #18).

Lighting and DarkSky International
The term “dark sky” generally refers to movement and achievement of significant reduction in light pollution so that the sky returns or becomes closer to its natural nighttime darkness.

Jurisdictions can implement regulations to decrease light pollution, and many cities have adopted “dark sky” ordinances to reduce light pollution. Advocates of “dark sky” policies cite a number of advantages, including:

1. Support of the body’s natural circadian rhythm, promoting better sleep.

2. Reduction of glare, improving safety and comfort at night.

3. Protection of nocturnal species, who rely on natural darkness for navigation, mating cycles, and foraging.

4. Support of plant cycles, which rely on periods of light and darkness.

5. Conservation of energy, by only using what light is necessary.

6. Reduction of light pollution, enhancing the beauty of the night sky.

DarkSky International is a recognized worldwide authority combatting light pollution.1 The organization publishes guidance for communities seeking to achieve a “dark sky” and decrease light pollution. The framework focuses on principles, which have been incorporated into the proposed ordinance:

1. Useful: Use light only if it is needed. All light should have a clear purpose. Consider how the use of light would impact the area, including wildlife and their habitat.

2. Targeted: Direct light so it falls only where needed. Use shielding and careful aiming to target the direction of the light beam so that it points downward and does not spill beyond where it is needed.
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3. Low Level: Light should be no brighter than necessary. Use the lowest light level required. Be mindful of surface conditions, as some surfaces may reflect more light into the night sky than intended.

4. Controlled: Use light only when it is needed. Use controls such as timers or motion detectors to ensure that light is available when it is needed, dimmed when possible, and turned off when not needed.

5. Warm-colored: Use warmer color lights where possible. Limit the amount of shorter wavelength (blue-violet) light to the least amount needed.

Previous City Council Discussion
On April 7, 2025,3 staff presented its recommendation for the Lighting Ordinance update, which differed from the Planning and Transportation Commission’s recommendation of October 30, 2024. Staff clarified that its recommendations primarily centered around concerns regarding impacts on enforcement and implementation once adopted. After deliberation, the City Council directed staff to return with several modifications, including requiring that new standards apply to replacement of existing lighting; allowing additional exceptions; and increasing efforts to raise awareness. These modifications aligned with most of the PTC recommendations and included requirements to be applied to all existing lighting, similar to the City of Brisbane. The City Council motion and staff analysis is provided below.

ANALYSIS
On April 7, 2025, the City Council directed staff to revise the draft ordinance for greater consistency with the recommendations made by the Planning and Transportation Commission in October 2024. The City Council’s motion items are italicized below, and staff descriptions on how each was incorporated into the draft ordinance follow each element of the motion:

MOTION:

A. Ensure protections in the existing code are not eroded for existing outdoor lighting in all zoning districts.
a. Retain the Requirements and Guidelines that the current municipal code provides to riparian ecosystems section 18.40.140.

No revisions needed as the updated ordinance provides equivalent or greater protection from light pollution compared to the existing outdoor lighting requirements. Additionally, the existing provisions and requirements in PAMC

18.40.140 will remain until the Stream Corridor Protection Ordinance Update is adopted.
3 Link to the City Council agenda for the public hearing on April 7, 2025 (Item #17):
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B. Require this ordinance apply to all new or replacement outdoor lighting consistent with the Planning and Transportation Commission (PTC) motion of October 30th to include:
a. Installation of new outdoor lighting, replacement of existing outdoor lighting fixtures, or changing the lighting type or system;
Incorporated in Section 18.40.250(c). The language from the motion was added to the applicability section.
b. for replacement lighting fixtures on buildings and structures, develop a hardship exception provision that would consider technical feasibility or financial burden to only apply to replacements on existing buildings and structures; and Incorporated in Section 18.40.250(j)(2). An exception can be requested if implementation of the lighting requirements more than doubles the cost of the project.
c. any existing nonconforming lighting after 10 years for residential and 5 years for nonresidential shall remain extinguished until brought into compliance with this ordinance.

Incorporated in Section 18.40.250(l). The deadline for existing lighting to comply with the new requirements is five years from the effective date of the ordinance for nonresidential zoning districts, and 10 years for residential and mixed-use zoning districts. Any existing lighting that has not been brought into compliance with the Code by these deadlines must remain extinguished (off) until it meets the new lighting standards.

C. Existing luminaires that have the technical capacity to be adjusted to comply with the ordinance without a need to change the fixture should comply within two (2) years of the effective date of the ordinance (i.e: fixtures that have existing dimmers, adjustable directionality, timers, Correlated Color Temperature adjusters, motion sensors, etc.).

Incorporated in Section 18.40.250(l)(2). The deadline for existing lighting to comply through use of existing features is two years from the ordinance's effective date. That lighting will be required to meet the new standards, with the exception of the shielding requirements.

D. Amend Section (4)(A) to include specific application of the curfew to all new, replacement, and existing outdoor luminaires.
a. Citywide and Holiday lighting curfew of midnight.

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Incorporated in Sections 18.40.250(d)(4) and 18.40.250(e)(4). The lighting curfew provision was revised to extend the turn-off time of all outdoor lighting to 12:00 a.m. Additionally, the seasonal lighting exception language was revised to explicitly state when such lighting is subject to extinguishment.

E. Implement the October 30th PTC motion regarding light trespass to change the light trespass from 0.5 to 0.1 foot candles at every reference throughout the ordinance.

Incorporated throughout the ordinance.

F. Incorporate into Section 1.B. Findings and Declarations, and Section 2 (a) Purpose, the Five Principles for Responsible Outdoor Lighting. One of the sections should include the full language of the principles.

Incorporated (Section 1B of the ordinance, and Section 18.40.250(a)(1)).

G. Develop an exception for special security concerns.

An exemption has been incorporated in the draft ordinance (Section 18.40.250(d)(7)) to address this direction, however without use of “special security concerns.” See below for further discussion of the specific approach presented.

H. Staff to return with recommendations on compliance mechanisms that would reduce the need for code enforcement – such as self-certification under business licenses, education through Utilities inserts, and potential adoption of a tool similar to Brisbane’s Good Neighbor Letter.

Potential measures are explained below for the City Council consideration, along with the pros and cons for each measure.

Exception for Special Security Concerns
During the April hearing, the City Council heard concerns from a community member about how the proposed new lighting standards might impact security, especially in their neighborhood along Edgewood Drive. A speaker noted that less or limited lighting could worsen existing security concerns for property owners in the neighborhood. In response, the City Council asked staff to look into allowing an exception for properties with heightened security concerns.

Staff worked with the City’s Police Department and reviewed crime information from the past year for areas near the San Francisquito Creek. While the information showed that crimes and calls for service do occur in this area, they were not significantly higher in the specific Item 15
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residential neighborhood mentioned compared to other areas of the City. The Police Department also confirmed that the City currently does not have any areas identified as having special concerns due to high crime rates, and there are not areas in Palo Alto that they would characterize as “high crime.” While crime data do not support the designation of specific areas as high security risk zones, staff recognize some residents may have heightened perceptions of safety concerns based on local conditions or experiences.

The Edgewood neighborhood does have unique characteristics that could justify different lighting standards including proximity to the creek, lot arrangements, and bordering another jurisdiction. As a result, to implement the Council’s direction, staff have included an exemption in the draft ordinance specific to the Edgewood neighborhood. While the draft ordinance currently exempts this neighborhood from the new outdoor lighting standards, the curfew requirement would still apply to the neighborhood, unless otherwise directed by the City Council.

Measures to Support Compliance
The City does not have sufficient resources to proactively enforce the new outdoor lighting ordinance. While staff will respond to egregious violations as capacity allows, most violations are expected to occur outside of typical Code Enforcement hours (i.e., at night), and staff are already managing a full caseload of other enforcement matters. Additionally, the compliance timelines established in the ordinance, as directed by the City Council, are unlikely to result in full compliance within the specified periods.

Staff remain concerned about establishing regulatory standards that cannot be reliably enforced, as this may lead to unrealistic expectations in the community regarding the extent of compliance that can be achieved.

Recognizing these challenges, the City Council directed staff to explore additional options to support a community-based approach to compliance. The following measures are not part of the ordinance itself but could be implemented after the ordinance is adopted:
Neighbor Letter Template: A letter template modeled on tools used by the City of Brisbane and DarkSky International could allow residents to inform neighbors about the ordinance and encourage voluntary compliance. While this may reduce initial complaints to the City, it relies on voluntary action and may lead to disputes or unprioritized reports.
Educational Materials: Staff will develop outreach materials, including online content, printed handouts, and utility bill inserts, to raise awareness about the new requirements. This approach aims to reduce inadvertent non-compliance through public education but has no direct enforcement effect and depends on public engagement. Affidavit Letter: Staff considered requiring applicants and property owners to sign an affidavit acknowledging awareness of the lighting requirements during the permit Item 15
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process. However, this approach would duplicate information already reviewed as part of plan review and introduce additional regulatory steps to the permitting process, and is therefore not recommended.

These supplemental efforts are intended to promote broader awareness and voluntary compliance in the absence of dedicated enforcement resources.

Exemption for City Facilities
Since this report was first published, staff have updated the ordinance to explicitly exempt lighting for streets, roadways, public walkways, and bikeways. This clarification ensures the City will not be required to modify its existing lighting infrastructure as a result of the ordinance.

An additional exemption authorizes the City Manager to exclude public facilities that operate 24 hours a day, seven days a week when such an exemption is necessary for facility operations or safety.

Together, these changes reflect the need to balance essential City operations and the safety and well-being of employees and the community with the City’s goal of reducing nighttime light pollution and promoting a healthier environment for wildlife.

Additional Minor Changes
To reduce redundancy, the Outdoor Security Lighting requirements previously found under the Special Purpose Lighting section were removed. These requirements largely duplicated the citywide outdoor lighting standards.

POLICY IMPLICATIONS
The Lighting Ordinance Update aligns with the Comprehensive Plan’s Natural Environment Element, which aims to preserve natural resources through sustainable practices and climate adaptation. Policy N-7.5 seeks to minimize light from development, Policy N-1.9 mandates shielding exterior lighting in foothills, and Program N3.3.3 requires the careful design of lighting surrounding natural riparian corridors. The ordinance improves nighttime visibility for wildlife, enhances energy efficiency and supports environmental protection and community health goals.

While not directly related to the Palo Alto Sustainability Climate Action Plan (S/CAP), the ordinance supports the goal of enhancing ecological resilience. It provides better habitats for nocturnal wildlife, aiding environmental conservation. Although not a specific S/CAP goal, the ordinance may reduce electricity usage, as outdoor lighting will have motion sensor controls, thus fostering sustainability and supporting S/CAP objectives.

Under Program 3.2 of the Housing Element, the City must analyze how new regulations impact housing production. The Lighting Ordinance is not expected to significantly affect housing, as it Item 15
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doesn't change density, layout, or height. Minor cost or design modifications may be needed for compliance, but dark sky products and lighting technologies are available.

FISCAL/RESOURCE IMPACT
Staff anticipate a misalignment in the community’s expectations to enforce this ordinance relative to existing code enforcement workload and resources. Except for documented isolated and egregious violations of the ordinance, staff will rely on low-cost supplemental measures such as a letter template that can be used between neighbors and potential educational materials to inform the community about requirements and standards.

STAKEHOLDER ENGAGEMENT
Staff conducted two study sessions, one in February and another in July 2024 through the ARB to provide a forum for community members to express their views and concerns regarding the proposed ordinance. In addition, staff have engaged with representatives from the Santa Clara Valley Audubon Society and Sierra Club Loma Prieta Chapter to solicit their input on the proposed ordinances.

On October 8, 2025, Staff conducted a focused outreach meeting with Palo Alto businesses and presented draft ordinance. A total of 38 participants attended this focused outreach meeting that was held virtually, and the participants included members of the Palo Alto Chamber of Commerce, Stanford University, and businesses/developers of Stanford lands. Several attendees expressed concerns about the requirement to bring all existing lighting up to the new standards, which could require expensive investments to completely redesign lighting plans.

Other members were concerned about safety implications of reducing lighting at commercial facilities that have overnight operations, noting specifically that Federal Occupational Safety and Health Administration (OSHA) workplace regulations would require lighted walkways, for example. The requirement for existing lighting to comply with the new lighting regulations in the ordinance was directed by the City Council at the April 7, 2025, meeting; as a result this requirement remains in the draft ordinance. However, the ordinance does include exceptions for lighting at building entrances, parking areas, walkways, and driveway areas, and safety requirements in Federal or State law (including OSHA regulations) will supersede this ordinance where required. The outreach meeting materials, including the staff presentation and recorded meeting, are available on the project website at www.PaloAlto.gov/OutdoorLighting.

Staff received numerous comment letters from the Santa Clara Valley Bird Alliance (formerly known as the Santa Clara Valley Audubon Society) and Sierra Club Loma Prieta Chapter on various versions of the draft ordinance presented to the ARB and PTC. These comments were considered and incorporated into draft ordinance throughout the process. The latest ordinance reflects many of the suggestions received.

At the time of staff report preparation, staff received one comment letter from a resident of Crescent Park. While supporting responsible outdoor lighting, the resident is opposed to the Item 15
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proposed Lighting ordinance update due to its overly restrictive nature, negative impact on safety, and lack of sufficient community input.

All public comments received for the draft lighting ordinance are in Attachment B.

Future Outreach
PTC recommended to the City Council that further outreach be done at the time of implementation, informing residents of the new regulations; and that regulations for interior commercial lighting be considered in the future. Unless directed otherwise, staff will inform the project’s interested parties about the ordinance adoption and provide a copy for review. Staff will also prepare information to be shared on the City’s website and at the Development Center regarding the new regulations and communicate as appropriate through other City communication channels. The City Council could also consider additional regulations for interior commercial lighting at future priority-setting sessions.

ENVIRONMENTAL REVIEW
The City has reviewed these proposed ordinances in accordance with that authority and criteria set forth in the California Environmental Quality Act. The City, as the lead agency, anticipates that these ordinances will be exempt from CEQA in accordance with CEQA Guidelines Section 15308, which includes actions by regulatory agencies for the protection of the environment.

ATTACHMENTS
Attachment A: Draft Ordinance Updating Lighting Standards (PAMC Section 18.40.250) Attachment B: Examples of Educational Materials and Template Neighbor Letters Attachment C: Public Comments received after the City Council hearing on April 7, 2025 APPROVED BY:

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Ordinance No. _____
Ordinance of the Council of the City of Palo Alto Repealing and Replacing Section

18.40.250 (Lighting) of Chapter 18.40 (General Standards and Exceptions) and Amending Chapters 18.10, 18.12, 18.28 and Section 18.40.230 of Title 18 (Zoning) of the Palo Alto Municipal Code to Adopt New Outdoor Lighting Regulations

The Council of the City of Palo Alto ORDAINS as follows:

SECTION 1. Findings and Declarations. The City Council finds and declares as follows:

A. The term “dark sky” generally refers to achievement of signiﬁcant reduction in light pollution so that the sky returns or becomes closer to its natural nighttime darkness.

B. Adhering to Dark Sky principles, which promote responsible outdoor lighting practices, can signiﬁcantly reduce light pollution and mitigate its harmful eﬀects. These principles emphasize using light only if it is needed, directing so that it falls only where it is needed, having lighting only when it is necessary and no brighter than necessary, and using warmer lights.

C. On January 29, 2024, the City Council selected four City Council priorities, one of which is the Climate Change & Natural Environment – Protection & Adaptation, and included an objective to “approve a bird safe glass and wildlife light pollution protections ordinance.”
D. On February 14, 2024, and July 18, 2024, the Architectural Review Board conducted study sessions and provided feedback on the concepts of the DarkSky regulations and draft ordinance.

E. On August 14, 2024, the Planning and Transportation Commission reviewed the draft ordinance, provided feedback and recommended that staﬀ return with more information, continuing the hearing to a date uncertain.

F. On October 30, 2024, the Planning and Transportation Commission recommended that City Council adopt the ordinance.

G. The ordinance aligns with Dark Sky principles and is intended to reduce light pollution at night, protecting wildlife and supporting a sustainable and resilient community.

/ /

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SECTION 2. Section 18.40.250 (Lighting) of Chapter 18.40 (General Standards and Exceptions) of Title 18 (Zoning) of the Palo Alto Municipal Code is repealed in its entirety and replaced with a new Section 18.40.250 (Lighting) to read as follows:

18.40.250 Lighting
(a) Purpose. The intent of this section is to establish exterior lighting standards to reduce light pollution. Exterior lighting of parking areas, pathways, and common open spaces, including fixtures on building facades and free-standing lighting should aim to:
(1) Reduce light pollution and its adverse effects on the environment, wildlife habitat, and human health through implementing Dark Sky Principles of responsible outdoor lighting that are useful, targeted, low level, controlled, and warm colored; (2) Minimize the visual impacts of lighting on abutting or nearby properties and from adjacent roadways;
(3) Provide safe and secure access on a site and adjacent pedestrian routes; (4) Achieve maximum energy efficiency; and
(5) Complement the architectural design of the project. (b) Definitions. For purposes of this chapter, the following words and phrases are defined as follows:
(1) “Correlated Color Temperature” or “Color Temperature” means a specification of the color appearance of the light emitted by a light source, measured in Kelvin (K).

Warmer color temperatures are a lower number, and cooler color temperatures are a higher number.
(2) “Fully Shielded” means a luminaire constructed and installed in such a manner that all light emitted, either directly from the lamp or a diffusing element, or indirectly by reflection or refraction from any part of the luminaire, is projected below the horizontal plane extending from the bottom of the lamp. (3) “Glare” means light entering the eye directly from a luminaire or indirectly from reflective surfaces that causes visual discomfort or reduced visibility to a person. (4) “Lamp” means, in generic terms, a source light, often called a “bulb” or “tube.” Examples include incandescent, fluorescent, high-intensity discharge (HID) lamps, and low-pressure sodium (LPS) lamps, as well as light-emitting diode (LED) modules and arrays.
(5) “Light pollution” means the material adverse effect of artificial light, including, but not limited to, glare, light trespass, sky glow, energy waste, compromised safety and security, and impacts on the nocturnal environment, including light sources that are left on when they no longer serve a useful function.

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(6) “Lumen” means the common unit of measure used to quantify the amount of visible light produced by a lamp or emitted from a luminaire (as distinct from “Watt,” a measure of power consumption).
(7) “Luminaire” means outdoor illuminating devices, lamps, and similar devices, including solar powered lights, and all parts used to distribute the light and/or protect the lamp, permanently installed or portable.
(8) “Seasonal lighting” means lighting installed and operated in connection with holidays or traditions within the time period speciﬁed in Section 18.40.250(d)(4). String lighting used outside these periods is not considered seasonal lighting and shall be subject to requirements in Section 18.40.250(f)(6).
(9) “String lighting” means light sources connected by free-strung wires or inside of tubing resulting in several or many points of light.
(c) Applicability. Except as otherwise provided in subsections (d) and (e)(4)(A) below, the outdoor lighting standards and guidelines set forth in this Section shall apply to the following projects:
(1) All newly constructed structures and buildings; or
(2) Structures or buildings proposing a Substantial Remodel, as defined in Section

16.14.070; or
(3) If a building permit is required: New installation of outdoor luminaires, replacement of existing outdoor luminaires, or modifications to the lighting type or system. (4) All existing outdoor light fixtures installed prior to the effective date of this ordinance shall conform to the provisions of this ordinance according to the compliance schedule set forth in Section 18.40.250(l).
(d) Exemptions. The following types of lighting are exempt from the lighting requirements of the section:
(1) Illuminated street numbers;
(2) Temporary construction or lighting for emergency personnel; (3) Lighting authorized by a special event, special or temporary use permit; (4) Seasonal lighting, subject to extinguishment at 12:00 a.m., during the period of October 15 through January 15 of each year;
(5) Lighting for Airport Operations. Nothing in this section shall be interpreted to restrict, limit, or otherwise regulate lighting that, in the reasonable judgment of the Airport Manager, is prudent or necessary for airport operations, airport safety, or air navigation in connection with operations at the Palo Alto Municipal Airport; or Item 15
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(6) Lighting for Emergency Shelters. Lighting for emergency shelters shall be subject to PAMC 18.14.060.
(7) Single family residential sites adjacent to San Francisquito Creek and fronting on Edgewood Drive if the portion of the site subject to a permanent easement in favor of the Santa Clara Valley Water District (or its successor in interest) for flood control purposes is reconfigured after January 1, 2002. These sites shall be subject to the requirements under Section 18.40.250(e)(4)(A).
(8) Lighting for streets, roadways, and public walkways and bikeways. (9) Lighting for Public Facilities Operations. Nothing in this section shall be interpreted to restrict, limit, or otherwise regulate lighting that, in the reasonable judgment of the City Manager, is prudent or necessary for operations or safety of public facilities that operate on a 24 hours per day, 7 days a week basis. (e) Lighting Standards.
(1) Shielding
(A) All outdoor lighting shall be fully shielded and directed to avoid light trespass. No lighting shall trespass more than 0.1-foot candle as measured at the property line.
(B) Exceptions for shielding requirements shall be applied to the following types of lighting:
(i) Low voltage landscape uplighting used to illuminate fountains, shrubbery, trees, and walkways, outdoor art or public monuments provided that they use no more than a 10-watt incandescent bulb or LED equivalent or emit no more than 150 lumens. These luminaires may not direct light towards the public right-of-way;
(ii) Sidewalk-facing lighting for zero lot line developments, provided the luminaires are motion-activated and automatically extinguish within five minutes without further activation; or
(iii) String lighting pursuant to Section 18.40.250(f)(5). (2) Parking Lot Lighting Height.
(A) Exterior lighting fixtures shall be mounted less than or equal to 15 feet from grade to top of fixture in parking lots in residential development and 20 feet in parking lots with commercial and mixed-use development. / /

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(3) Illumination Level and Color Temperature
(A) All light sources shall have a correlated color temperature of 2,700 Kelvin or less. (B) The maximum outdoor light intensity on a site shall not exceed an average value of 5 foot-candles.
(4) Lighting Control.
(A) Lighting Curfew. Unlike other provisions in this section, the Lighting Curfew shall apply to all outdoor luminaires for new and existing buildings and structures, unless otherwise approved. All outdoor lighting shall be fully extinguished or be motion sensor operated by 12:00 a.m., two hours after the close of business, or when people are no longer present in exterior areas, whichever is later. (B) All lighting activated by motion sensor shall be set up to extinguish after no more than five minutes without further activation.
(C) All lighting shall be automatically extinguished using a control device or system when there is sufficient daylight available, except for lighting under canopies or lighting for tunnels, parking garages, or garage entrances. (D) Exceptions for Lighting Control.
(i) Any lighting at building entrances, parking areas, walkways, and driveways area;
(ii) Outdoor pathway lights that emit 25 lumens or less; or (iii) Lighting that illuminates a pedestrian pathway (examples include bollard, in-place step, or building mounted), provided that such lighting is a maximum height of four (4) feet above the pathway and fully shielded. (f) Special Purpose Lighting. The standards in this section shall prevail over any conflicting standard in subsection (e).
(1) Low Density Residential Lighting. In addition to the lighting standards in the section, the following lighting requirements shall be applicable to projects in R-1, R-2, RE, RMD, NV- R1, or NV-R2.
(A) When abutting any residential use, no spillover of lighting to adjacent properties shall be allowed.
(B) A maximum of 1,260 lumens shall be allowed for each fully shielded outdoor lighting. No more than 420 lumens shall be allowed for permitted non-shielded outdoor lighting.
(C) Skylights shall limit illuminance and glare during night hours. Glare shall be mitigated through the use of translucent glass, shading systems, and interior light placement.

Skylights shall not use white glass.

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(D) Height for Recreational and Security Lighting. Free-standing lighting shall be a maximum of twelve feet (12’) in height for those that were installed on or after March 11, 1991.
(2) Athletic Facilities Lighting. Outdoor athletic facilities shall conform to the following standards:
(A) Field lighting is provided exclusively for illumination of the surface of play and viewing stands, and adjacent proximity areas for public safety. (B) Illumination levels shall be adjustable based on the task (e.g., active play vs. field maintenance).
(C) Off-site impacts of the lighting will be limited to the greatest practical extent possible.
(D) Lights shall be extinguished by 10:30 p.m. except when the facilities are being used for active play and maintenance before or after permitted events, and the lights are equipped with a timer.
(E) Timers that automatically extinguish lights shall be installed to prevent lights being left on accidentally overnight.
(3) Automobile Service Station Lighting
(A) Lighting fixtures in the ceiling of canopies shall be fully recessed or mounted directly to the underside of the canopy. All luminaires shall be located so that no lighting is directed towards the adjoining property or public rights-of-way. (B) Luminaires are not permitted on top of the canopy fascia. (C) The maximum light intensity under the canopy shall not exceed an average foot- candle of 12.5, when measured at finished grade.
(D) No free-standing lighting shall be higher than 15 feet above finished grade. (E) The canopy fascia shall not be illuminated.
(4) Outdoor Space Above Ground Floor.

These requirements apply to all outdoor spaces
located above ground level, including, but not limited to, rooftop gardens, rooftop restaurants or bars, balconies, and decks.
(A) Any lighting shall be shielded from public views and any luminaires shall be fully shielded and no uplighting shall be permitted.
(B) Lights shall be dimmable to control glare and placed on timers to turn off after 10:00 p.m. or as permitted pursuant to Section 18.40.250(e)(4)(D) (C) No light trespass shall be allowed more than 0.1 foot-candle as measured beyond the perimeter of the roof deck or other outdoor space above the ground floor.

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(5) String Lighting.
(A) String lighting color temperature shall not exceed 2,700 Kelvin and no individual lamp that is part of a string lighting installation shall exceed a rating of 42 lumens.

No string lighting shall be blinking, flashing, or chasing. (B) For commercial and mixed-use areas, string lighting shall be limited to designated outside dining or display areas or common open space (i.e. courtyard or patio). (6) Parklets. Lighting for any parklets shall comply with the lighting standards established in the Permanent Parklet Program.
(g) Prohibited Lighting. The following types of lighting are prohibited except when used by emergency service personnel during an emergency:
(1) Outdoor lighting that blinks, flashes, or rotates; or (2) Searchlights, aerial lasers, or spotlights.
(h) Lighting for Signs. See Chapter 16.20 for lighting requirements for signs. (i) Additional Provisions and Conflict Precedence. Lighting required by the Building Code, Fire Code, or state or federal law shall additionally comply with the requirements of this section, unless these requirements necessarily conflict with the aforementioned Codes and laws. In the event of a conflict, the standards in the applicable Codes and laws shall prevail. (j) Hardship Exceptions. The Director may grant an exception from the requirements in Section

18.40.250, if a project applicant provides evidence demonstrating one of the following hardships:
(1) Implementation of the lighting requirements in this ordinance would impair the historical integrity and character-defining features of the building and create an adverse impact to the building’s historical, architectural, and cultural significance; or (2) Implementation of the lighting requirements in this ordinance would more than double the cost of the project. This exception shall apply only for replacement of existing outdoor luminaires or changing the lighting type or system that requires a building permit.
(k) Public Facilities. Unless exempt under Section 18.40.250(d), Public Facilities, including City- owned and operated facilities, shall comply with the outdoor lighting standards of this Section to the extent feasible. The Director may grant adjustments to any applicable lighting standards for such facilities if the adjustment is necessary for the efficient operation, maintenance, or safety of the facility, or to ensure public safety and security; and is consistent with the overall intent and purpose of this Section. A written request for an adjustment, including supporting documentation, shall be submitted and shall be reviewed according to the applicable review procedures in PAMC Section 18.77 associated with the proposed development.

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(l) Existing Nonconforming Lighting.
(1) Within two years of [the effective date of this ordinance]: Where existing outdoor luminaires have the ability to adjust (through existing dimmers, directional adjustability, timers, etc.), the requirements under Section 18.40.140(e), except for the shielding requirements under the subsection 18.40.140(e)(1), shall apply. (2) Fo r all existing outdoor luminaires, t he requirements under Section 18.40.140(e) shall apply within the following timeframes from [the effective date of this ordinance]:
(A) Residential and Mixed Use Zoning Districts: Within ten years. (B) Nonresidential Zoning Districts: Within five years. (3) Any nonconforming lighting still in place after the compliance deadline shall remain extinguished at all times until they are brought into compliance.

SECTION 3. Subsection (e) of Section 18.40.230 (Rooftop Gardens) of Chapter 18.40 (General Standards and Exceptions) of Title 18 (Zoning) of the Palo Alto Municipal Code is amended to read as follows (additions underlined; deletions struck-through):
(e) Any lighting shall be shielded from public views and have full cutoff fixtures that cast downward-facing light, or consist of low-level string lights; no up-lighting is permitted. Lights shall be dimmable to control glare and placed on timers to turn off after 10:00 p.m.

Photometric diagrams must be submitted by the applicant to ensure there are no spillover impacts into windows or openings of adjacent properties.For lighting requirements, refer to Section 18.40.250.

SECTION 4. Subsection (g) of Section 18.10.040 (Development Standards) of Chapter

18.10 (Low Density Residential (RE, R-2 and RMD) Districts) of Title 18 (Zoning) of the Palo Alto Municipal Code is amended to read as follows (additions underlined; deletions struck-through):
(g) Lighting in R-2 District
In the R-2 district, recreational and security lighting shall be permitted only so long as the lighting is shielded so that the direct light does not extend beyond the property where it is located. Free- standing recreational and security lighting installed on or later than March 11, 1991, shall be restricted to twelve feet (12') in height. For lighting requirements, refer to Section 18.40.250.

SECTION 5. Subsection (k) of Section 18.12.040 (Site Development Standards) of Chapter 18.12 (R-1 Single-Family Residential District) of Title 18 (Zoning) of the Palo Alto Municipal Code is amended to read as follows (additions underlined; deletions struck-through):
(k) Lighting
Recreational and security lighting shall be permitted only so long as the lighting is shielded so that the direct light does not extend beyond the property where it is located. Free-standing recreational and security lighting installed on or later than March 11, 1991 shall be restricted to twelve feet (12') in height. Direct light from outdoor fixtures shall only fall on the walls, eaves, Item 15
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*** NOT YET APPROVED ***

9 0160151_20250821_ay16

and yard areas of the site on which it is located. Outdoor fixtures shall have lens covers or reflectors that direct the light away from the neighboring properties. For lighting requirements, refer to Section 18.40.250.

SECTION 6. Subsection (n) of Section 18.28.270 (Additional OS District Regulations) of Chapter 18.28 (Special Purpose Districts) of Title 18 (Zoning) of the Palo Alto Municipal Code is amended to read as follows (additions underlined; deletions struck-through):
(n) Light and Glare
Exterior lighting should be low-intensity and shielded from view so it is not directly visible from off-site. The light emitted from skylights shall be minimal during the night hours. Utilizing treatments such as translucent glass, shading systems, and interior light placement can reduce the night glare. Skylights shall not use white glass. For lighting requirements, refer to Section

18.40.250.

SECTION 7. If any section, subsection, clause or phrase of this Ordinance is for any reason held to be invalid, such decision shall not affect the validity of the remaining portion or sections of the Ordinance. The Council hereby declares that it should have adopted the Ordinance and each section, subsection, sentence, clause or phrase thereof irrespective of the fact that any one or more sections, subsections, sentences, clauses or phrases be declared invalid.

SECTION 8. The Council finds that this project is exempt from the provisions of the California Environmental Quality Act (“CEQA”), pursuant to Section 15061 of the CEQA Guidelines, because it can be seen with certainty that there is no possibility that the ordinance will have a significant effect on the environment and Section 15308, as an action by a regulatory agency to protect the environment.

SECTION 9. This ordinance shall be effective on the thirty-first day following its adoption.
/ /

/ /

Item 15
Attachment A - Draft
Ordinance Updating
Lighting Standards (PAMC
Section 18.40.250)

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SECTION 10. This Ordinance shall not apply to any project application deemed complete prior to the effective date of this Ordinance.

INTRODUCED:

PASSED:

AYES:

NOES:

ABSENT:

ABSTENTIONS:

NOT PARTICIPATING:

ATTEST:

____________________________                     ____________________________ City Clerk                                                             Mayor

APPROVED AS TO FORM:                                    APPROVED:

____________________________                     ____________________________ Assistant City Attorney                                    City Manager

____________________________
Director of Planning & Development
Services
Item 15
Attachment A - Draft
Ordinance Updating
Lighting Standards (PAMC
Section 18.40.250)

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Have you heard? The City of Brisbane passed a “Dark Sky Ordinance” that regulates outdoor lighting.

You may not be aware of this, but your lights are:
too bright
shining in our window
interfering with our sleep
________________
________________

Please consider:
directing your lights downward
shielding the lamp
using a lower wattage bulb
using a “warmer” color temperature
using motion sensor and/or timer
________________

I would be willing to help with the cost and/or implementation of changes.

In addition to helping us out, these actions can help bring you into compliance with the City’s ordinance, reduce light pollution, and improve the environment.

Thanks so much for your time and understanding!
- your concerned neighbor
Learn more at brisbaneca.org/darksky
Adapted by OSEC from darksky.org/resources/what-is-light-pollution/light-pollution-solutions/lighting/my-neighbors-lighting/ Dear Neighbor...

Shielding reduces glare that can be dangerous and
unsafe. Glare can be blinding and create harsh
shadows where “bad guys” can hide. Shielded lighting
provides real security, not just the illusion of security, which I think we both want for our families and friends.

There are several other ways to improve lighting, save
money, and still be safe. One is using motion sensors,
which alert you if someone is in your yard after dark
and have the added benefit of reducing your electric
bills by keeping the lights off when they’re not needed.

Timers are another way to save money because these
devices turn off your lights when they’re not needed,
for example, when you retire for the night.

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[Date]
Dear [insert neighbor’s name],

I’m your neighbor [insert your name] at [address], and I would love to talk with you about good outdoor lighting. I notice that you have installed outdoor lights on your property, and I applaud your desire to help improve our neighborhood.

You may not have realized that some of your lights are a bit too bright and shine in [pick areas as they apply: our bedroom window, the backyard, into our house etc.] and interfere with our [sleep, hobbies, view of the sky, etc.]. I don’t wish to tell you what to do with your home, but I’m hoping we can openly discuss this and come to a compromise that fulfills and respects everyone’s needs.

Please understand I’m not asking you to remove the lights, but perhaps make subtle changes that will work for everyone.

One idea would be redirecting the light by shielding the fixtures so that they are even more effective. Unshielded lamps create dangerous glare — this glare causes harsh shadows which can blind you to real, hidden hazards such as unwanted visitors (see pictures below). On the other hand, shielded lighting provides real security (not just the illusion of security) which I think we both want for our homes. As an extra benefit, shielding a lamp usually involves a lower wattage bulb, which would be a money-saver on your electric bill.

There are several other ways to improve lighting, save money, and still be safe. One is using motion sensors, which alert you if someone is in your yard after dark, and also reduce your electric bills by keeping the lights off when not needed. Timers are another way to save money, since they can automatically turn off your outdoor lights when you go to bed.

Thank you so much for your time and understanding! I would love to talk with you about how I can help, and how lighting changes can benefit your safety, budget, and the night sky.

Sincerely,
[your name]
[contact info]

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Shielded lights protect the night.

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Protect
the night
Preserving and restoring the
natural nighttime environment is
more urgent than ever.

Light pollution continues to grow at an alarming
rate, harming our health, damaging the
environment, and diminishing our view of the stars.

DarkSky International has a plan to save the night,
but we need your help.

The stars are disappearing
Join the movement and help
save the night
DarkSky is a global community
working together to save the night.

Sign-up today for DarkSky e-news
updates to learn more.

DarkSky International is a U.S.-based 501(c)(3) nonprofit that supports a global community and movement
dedicated to preserving and protecting the natural
nighttime environment.

DarkSky International
5049 East Broadway Blvd #105
Tucson AZ 85711
USA
www.DarkSky.org
+1-520-293-3198
Light pollution isreversible!
Unlike other forms of pollution, light pollution is a
problem with solutions that are easy to implement.

These solutions deliver immediate and lasting
results.

SUCCESS STORY
In 2018, the City of Tucson,
Arizona, U.S.A. (population
500,000) upgraded its
streetlights. By doing so, it
saved $2.2 million per year in
energy costs and reduced
light pollution by 7%.

WE’RE MAKING AN IMPACT
1,000+
More than 1,000 DarkSky
Approved lighting fixtures are
available on the market.
2,000+
DarkSky supports more than
2,000 volunteer Advocates in
49 countries.
70+
DarkSky supports more than
70 chapters in 24 countries.
200+
More than 200 International
Dark Sky Places have been
certified, protecting over
160,000 sq km of dark places
around the globe.

Photo credit: Bin Chen
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Light pollution...

What is light pollution?
Light pollution is the human-made alteration of outdoor light levels from those occurring naturally. When we over-light, fail to use timers and sensors, or use the wrong color of light, we negatively affect many parts of our world.

Destroys critical wildlife habitat
Plants and animals depend on
Earth’s daily light and dark
cycle to govern life-sustaining
behaviors. Research shows
that artificial light at night has
adverse and even deadly
effects on many species.

Wastes energy and money
Most outdoor lighting is
wasted. This energy waste
increases greenhouse gas
emissions contributing to
climate change and wastes
billions of dollars each year.

Harms human health
Studies indicate that artificial
light at night negatively affects
human health by increasing
our risks for obesity, sleep
disorders, depression,
diabetes, breast cancer, and
more.

Decreases safety and security
There is no clear scientific
evidence that increased
outdoor lighting deters crime.

In fact, glare from unshielded
streetlights can decrease
personal safety, contributing
to both crime and accidents.

Robs us of our night sky heritage
Our ancestors experienced a
night sky that inspired science,
religion, philosophy, art, and
literature. Now, millions of
children across the globe will
never know the wonder of
seeing the Milky Way.

Inhibits scientific research
Satellites in low Earth orbit
create visible trails in the night
sky, inhibiting astronomical
research and jeopardizing
NASA’s early warning system
for asteroid collisions.

What can I do?
DarkSky’s Five Principles for Responsible
Outdoor Lighting can help you make smart
choices to reduce light pollution. Do your
lights protect the night?
All light should have a clear purpose.

Use lights only when and where they
are needed.

Shield and aim your light so it only
falls downward and where it is
useful.

Lights should be no brighter than
necessary to save money and
reduce glare.

Lights should only be on when
needed. Use timers and motions
sensors.

Warm-colored light causes less
skyglow. Use amber-toned lights
whenever possible.

Is it useful?
Is it targeted?
Is it low-level?
Is it controlled?
Is it warm-colored?
Visit darksky.org to learn more
about the importance of the night
and what you can do to reduce
light pollution around your home
and community.

Learn more
Learn more about light pollution
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1441 Edgewood Dr
Palo Alto, CA 94301
April 26, 2025

Kelly Cha
Senior Planner
Planning and Development Services
250 Hamilton Avenue, Fifth Floor
Palo Alto, CA 94301

RE: Outdoor Lighting Update (“Dark Sky”)

Dear Ms. Cha:

I shared in my prior letters to you and city staff (“Staff”), the Planning & Transportation Committee (“PTC”), and the City Council for the City of Palo Alto (“City Council”) my opposition to the proposed lighting ordinance currently under consideration. I watched with great sadness the City Council on April 7, 2025 pass a motion to incorporate even more egregious conditions into the poorly drafted outdoor lighting ordinance, particularly the expansion to cover any existing light after 10 years.

As Staff prepares a new draft ordinance responsive to the City Council’s motion, I ask Staff to consider the following:

 Deep security concerns. Residents of Edgewood Dr have a valid and deep concern about safety and security given the frequent and repeated crime we and our property face, the growing unhoused population living immediately adjacent in the San Francisquito Creek (“Creek”) combined with the City’s unwillingness or inability to address the growing issue, and our immediate proximity to East Palo and the spillover impact of frequent crime. The most obvious remedy is to exempt houses on this street from the ordinance or significant portions of the ordinance. While I appreciate Staff’s concern with defining a “high crime” neighborhood, it is vital that the City Council’s direction to address those with “special security concerns” provides adequate relief for homeowners abutting the Creek to install and operate sufficient lighting to protect ourselves. I am terrified of the safety issues my wife and young daughter will face returning to a dark house, trying to take out the trash through a dark backyard, as they are forced to navigate an unlit pool, or are unable to see criminals accessing our yard. Through expensive renovations we can mitigate some of the safety issues caused by this poor ordinance, some of the most severe will remain. Fear for our safety and security is heightened when combined with the other ordinances also under consideration – imagine being forced to no longer allowed have adequate outdoor lighting, no longer allowed to maintain a fence separating you from criminals and unhoused population, and then having to cover your windows in dots so you cannot even see the criminals concealed in the darkness with unfettered access to your backyard. These ordinances, individually and collectively, greatly compromise our safety and security. Please understand these fears are very real for us; we have even started to look at buying firearms and obtaining conceal and carry permits just so we can come home at night!

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 Cost to comply exception / legal challenges and taking claim. With the expansion to cover all existing fixtures, the City must add an exception for properties that would incur excess cost to comply. After years of planning and building, I recently completed construction of my brand new home which I previously expected to be our family’s “forever” home. The preliminary estimate to comply with the new draft code as written requires that I destroy approximately $90,000 of lighting (and fan) materials and spend approximately $210,000 in new materials and labor. (This is just for the fixtures and related costs. The systems upgrades described later add further to this loss.) In 10 years, this would represent approximately $350,000 or more of expense (based on forecasted inflation rates). I can only imagine how much worse that will get with most of these fixtures and luminaires manufactured overseas. Imposing such extraordinary costs on homeowners is patently unfair. Would you want to have to work for 1-2 years just to comply with a new ordinance passed by the city? While my costs may be greater than some others, the cost to completely replace exterior lights for homeowners across Palo Alto is likely to be extremely high and grossly underestimated by City Council. Do we really want to pass this cost to so many homeowners? Do we really want to produce this much waste? A hardship exemption for only a temporary period of time, or requiring proof of financial distress, is wholly insufficient to remedy this loss. A cost to comply exemption is needed. Absent such an exception, it is paramount Staff and the City Attorney advise the City Council that passing such an ordinance leaves the city liable for a takings claim. While it is not my preference, please understand that passing an ordinance with a present value cost to me of $210,000 leaves me with no recourse but to challenge of the ordinance’s validity in court and assert a takings claim against the City for the entirety of this loss.

 Shielding standard for non-confirming lighting after 10 years. The overwhelming majority of the costs noted above arise from the shielding requirement applied to non-conforming lights after 10 years.

One of the primary stated objectives of the ordinance is to reduce light pollution and minimize visual impact to neighbors. If the 10 year restriction is included in the next draft ordinance, I strongly recommend and beg to allow non-shielded lights so long as their lux output (as measured at the property border) satisfies the light trespass requirements (previously 0.5 lux but now proposed to be 0.1 lux). Like many homeowners, this would mean I would not be required to replace every fixture and could instead replace the luminaire and/or use dimming to bring existing fixtures into compliance. While this would not completely solve glare, this would meet the primary objectives of the ordinance with far reduced cost to homeowners. Moreover, this would further benefit the community since many fixtures would then have the “technical capacity” to comply under the 2 year window rather than waiting the full 10 years.

 Lighting output measurement lumens vs lux. Most of the restrictions in the proposed ordinance 18.40.250 are written with regard to “lumens” of output. The original draft ordinance applied to new construction or new luminaires. As such, “lumens” was chosen presumably to make it easier for buyers to select luminaires with said rated lumens output (and for Staff to validate those specs during Planning). Now that the code will extend to existing luminaires, it is vital the code also express the limits in lux. It is my understanding that measuring lumen must be performed in a laboratory. I am told it is not practical to measure lumen output of an existing luminaire in the field. The could would therefore set a standard that could not be objectively measured by code enforcement either. Moreover, lumen is often the theoretical maximum which Item 15
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is reduced by the quality of the actual luminaire, the power system, distance, and other factors.

One important benefit of expressing output in lux is that it will also allow lighting designers to construct systems with dimmed lights. Most lighting systems are better served running well below 100% of maximum output to extend the lifetime of transformers and luminaires, therefore reducing cost and waste. Most importantly, it will fixtures with luminaires that cannot comply by lumen to comply through dimming. For example, I have two outdoor fan with a down light, adjustable color that can be made to work at 2700K or less, but with lumen that is too high. The manufacturer does not make a down light that meets the lumen requirements. The light, however, is dimmable and could remain if a lux threshold were established.

 Conflict in 18.40.250(f)(1)(B) with 18.40.250(e)(1). The draft ordinance 18.40.250(f)(1)(B) states that “No more than 420 lumens shall be allowed for permitted non-shielded outdoor lighting.” The drafting suggests the intent of this section is to allow non-shielded low voltage outdoor lights so long as the luminaire is less than or equal to 420 lumens. Section 18.250(f)(1) also states that low density outdoor residential lights are subject both to that constraint and all others. Section 18.40.250(e)(1)(B) states that all lights must be fully shielded unless it is low voltage up-lights with no more than 150 lumen. This presents a conflict that must be resolved. In the context of this ordinance, the 420 lumens output is most appropriate limit.

 Exemptions for front porch. The draft ordinance 18.40.250(d) provides a list of exemptions, including for illuminated street numbers. This exemption presumably recognizes the legitimate public safety need for first responders to locate a property in the event of an emergency. I would contend that providing safety lighting at a property’s front door is a similar legitimate public safety need. Lighting at a home’s primary ingress and egress is of importance to guests, first responders, and others. For most properties, it is impractical to install motion sensors on a front porch. Given this ordinance is being applied to an urban center, lighting the front porch should be exempted, at least with regard to curfew.

 Outdoor security light output. The outdoor security lighting output proposed in

18.40.250(f)(2)(D) is limited to 1,600 lumens. First, this is grossly inadequate for security light output over large areas. The result would force homeowners to install multiple security lights, which is both expensive and likely to be worse for light pollution (not to mention potentially more false positives). Instead, this section for outdoor security lights should be limited only to lux light trespass only as already provided in 18.40.250(f)(2)(C). Therefore, sub-paragraph (D) should be removed. It is worth nothing this change would greatly aid Edgewood residents with a legitimate safety need.

 Outdoor security light programmability. The draft code 18.40.250(f)(2)(A) requires outdoor lights to be “fully programmable.” It is entirely unclear from the code, common knowledge, or from consulting experts as to what “fully programmable” means with respect to an outdoor security light. This statement should be removed.

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 Outdoor kitchen lighting. The draft code 18.40.250(e)(3)(A) requires all outdoor lights to be 2,700K or less. Lighting professionals routinely recommend 3,000K for kitchens for safety. As with others, my brand new construction followed the lighting professionals’ recommendation and installed 3,000K luminaires in down lights at the outdoor kitchen (with all other outdoor lights of 2,700K). To promote safety, and in consideration that these are not decorative lights but instead task lights for preparing food, it would be reasonable to allow 3,000K luminaires in such down lights when they illuminate an outdoor kitchen.

 Control light sensor. The draft code 18.40.250(e)(4)(C) requires lighting control systems to have a light sensor. As noted elsewhere, I recently built a new home. The residence includes a whole-house lighting control system from a well-known manufacturer. The professional lighting designers hired for the project all systematically recommended against a light sensor on the roof for the whole house system given their poor sensitivity and likelihood of failure. They instead all universally recommended time-based automation. In fact, the most common light sensor from the manufacturer used was discontinued years ago because they are so infrequently installed in today’s lighting control systems. The draft code already provides for time-based extinguishing of lights. Therefore, the only practical purpose of this provision is with regard to when lights are allowed to turn on. I therefore recommend adding a time-based alternative to a light sensor.

Again, as a practical example, it will cost me approximately $25,000 to add a light sensor to the lighting control system (if I am unable to find the discontinued part, otherwise the cost will likely be over $1m to replace the entire lighting system), whereas it is a simple program change to set the lights to not come on until after a specific time of morning.

As noted at the start, I strongly oppose the current ordinance requested by the City Council. I am even more concerned about the cumulative impact of these ordinances: lighting update, bird design standard, and stream protection. Taken together, they effectively condemn my new home as unlivable while incurring massive costs.

The foregoing analysis offers several areas where this specific proposed lighting code update could be made substantially less burdensome without materially impacting the stated objectives.

Sincerely,

Tom Fountain
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1441 Edgewood Dr
Palo Alto, CA 94301
May 4, 2025

Kelly Cha
Senior Planner
Planning and Development Services
250 Hamilton Avenue, Fifth Floor
Palo Alto, CA 94301

RE: Outdoor Lighting Update (“Dark Sky”)

Dear Ms. Cha:

I am writing as a follow-up to my letter of April 26, 2025 regarding the City of Palo Alto’s (the “City”) proposed lighting update. As shared previously, I strongly oppose the proposed ordinance and was deeply disturbed by the direction of the City Council on April 7, 2025.

I spent my weekend attempting to apply the proposed ordinance to each of the outdoor luminaires and lamps on my property. As Staff prepares a new draft ordinance responsive to the City Council’s motion, I ask Staff to consider the following recommendations in addition to those shared previously:

 Measuring light output and promoting hex filters. The draft ordinance currently expresses lamp output limits in lumen. As noted in my prior letter, once extended to existing lamps, it is vital to instead measure the foot-candles (or lux) at the property border or express these limits as the maximum measured output in foot-candles at a specific distance. I also noted previously the importance of allowing field measurements to encourage dimming. This would significantly reduce the cost to property owners since existing lamping is often dimmable.

With or without either of these improvements to the draft code, please also consider allowing lighting designers to account for hexagonal cell louver filters (sometimes called “honeycomb” filters). Such filters significantly reduce glare and typically reduced effective light output by 20- 25% even though, by definition, the lamp’s lumen output is unchanged. Limiting output to a measured foot-candle value would account for filters without further change. If limits remain only in the lamp’s manufacturer-specified lumen, consider instead limiting output to the product of the lamp’s lumen times the effective light output if filtered. Alternatively, the lumen could be expressed both with and without a filter. For example, the low-voltage lighting might be limited to 150 lumen without a filter and 200 lumen when a hexagonal cell louver filter is installed. As a result, some property owners could install filters in existing luminaires and lamps rather than having to replace the entire luminaire and/or lamp. Taking hex filters into account would reduce the cost to comply with this proposed ordinance while simultaneously reducing glare and better achieving the stated objectives of the ordinance.

 Clarify low-voltage shield exception in 18.40.250(e)(1)(B)(i). The draft ordinance section

18.40.250(e)(1)(B)(i) is intended to provide an exception for unshielded low-voltage lighting.

The current draft states this exception applies only to “low voltage landscape uplighting” (underlined for emphasis). Limiting this exception to only “uplighting” is confusing and Item 15
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unnecessary. Presumably “uplighting” means anything that is not “Fully Shielded” but that is ambiguous from the context. Moreover, lighting designers should be encouraged, not discouraged, from using low voltage downlights even if they fail to fully satisfy the “Fully Shielded” definition. Consider as an example the FX Luminaire LED Wall Light (hƩps://www.fxl.com/product/wall-and-step-lights/designer/mo). Only one faceplate, the one identified as WW, qualifies as “Fully Shielded,” none would be easily identifiable as “uplighting,” yet all should be in the scope intended by the low-voltage shield exception.

Striking the word “uplighting” resolves this drafting issue.

 Correct fully shielded security lighting in 18.40.250(f)(2)(B). The draft ordinance

18.40.250(f)(2) is intended to allow outdoor security lighting that meets certain standards.

Section 18.40.250(f)(2)(B) establishes a height standard. The statement also requires that luminaire be “fully shielded”. Based on the definition of “Fully Shielded” provided in this draft ordinance, effectively no security light could comply. Compliance would require the light be installed such that lamps point straight down. Any projection “forward” of the luminaire would result in the lamp breaking the required plane extending from the bottom of said lamp. The requirement that these lights be “fully shielded” should be removed from this ordinance. If the intent of this phrase is to encourage security lights be aimed in a downward direction, then it should say so rather than reference “fully shielded” which has a specific definition.

 Address security perimeter lighting in 18.40.250(f)(2)(C). City Council directed Staff to replace all references to 0.5 foot-candle of spillover with 0.1 foot-candle of spillover. This change, even if applied elsewhere, should not be applied to this section. A limitation of 0.1 foot- candle effectively eliminates the use of security lighting near a fence. Even if aimed down, reflected light off other surfaces will exceed this threshold. It is untenable to have security lighting so limited where it is needed to illuminate an area near a fence.

 Correct typo shielding exception in 18.40.250(e)(1)(iii). Section 18.40.250(e)(1)(iii) provides an exemption for string lights and erroneously refers to 18.40.250(f)(5). It should instead refer to

18.40.250(f)(6).

Thank you for your continued work to craft an ordinance that does not create such negative impact to city residents.

Sincerely,

Tom Fountain
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City Council
Staff Report
From: City Manager
Report Type: INFORMATION REPORTS
Lead Department: City Manager
Meeting Date: December 8, 2025
Report #:2511-5462
TITLE
City of Palo Alto Organizational Values Refresh

RECOMMENDATION
This is an informational item; no action is needed

BACKGROUND
More than twenty years ago, the City established the organizational values of Quality, Courtesy, Efficiency, Integrity, and Innovation. As would be expected, having this values statement in place for such an extended period has led to a loss of connection to the current workforce and its organizational culture as reflected in the manner through which our staff conduct themselves in providing services to the Palo Alto community.

Much has shifted in recent years, especially since the pandemic changed the way we engage with each other, residents, businesses and other community members, and how we deliver services. As an agile and resilient organization, emerging from the pandemic provided a timely opportunity to revisit and refresh our core values, so they reflect our evolving culture, aspirations, and ways of working.

Organizational values can provide a clear and unifying statement that reflects and reinforces a shared sense of purpose, and the culture we choose to uphold. This can present a unique challenge to cities, given the range of services and interactions involved with municipal services, particularly for a full-service city such as Palo Alto. Undertaking an effort to refresh an organizational values statement can also be a challenge, as commitment to both extensive employee engagement in the effort and ongoing reinforcement following the project are required for the result to be credible and sustainable.

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Our approach to this undertaking was built on the foundation of the industry-leading “Special Projects Program” implemented as part of our Positive Work Environment initiative supporting organizational development coming out the pandemic. The Special Projects Program enabled staff from across the City to volunteer for projects that would help develop new skills on topics of interest. The Organizational Values Refresh project was undertaken during the second cycle of special projects. At this point the positive impact of the Special Projects Program had been established and broad workforce participation achieved. As an organizational development effort, this project is intended to complement and work in harmony with the Council Values reflected in the City Council Procedures and Protocols Handbook.

PROCESS OVERVIEW & EMPLOYEE ENGAGEMENT
The refresh of the City’s Organizational Values was guided by citywide efforts to strengthen employee engagement, inclusion, and an organizational culture that aligns with our evolving service delivery environment. This work is built on a framework of organizational and individual responsibility that integrates the dimensions of how we present ourselves and interact with others (People), how we view our work; our “why” (Purpose), and the methods and systems that guide our day-to-day actions (Practice).

To achieve the task, a structured six-month process was undertaken inviting voices from across our organization. Participants from each department and office were invited to join an Organizational Values Refresh special project team. Their role included serving as focus-group leaders, helping interpret input, and guiding departmental feedback with a citywide lens.

Every department held focus group discussions to address three key questions:
Are the existing values (Quality, Courtesy, Efficiency, Integrity, Innovation) still relevant? What additional values are essential for our organization to succeed in the current and future environment?
Which values help us serve our customers/clients and each other with integrity? What words or phrases represent the type of culture we want to create? To ensure every employee had the opportunity to participate and feedback was incorporated at every level of the organization, a citywide survey was distributed. The survey asked questions around employees’ perceptions of the current values, their alignment with the organization’s culture, and what values they believe should guide our future. The survey also solicited comments on how values could be exemplified in everyday practice.

The values team analyzed the survey results and distilled feedback into a set of four values.

They also generated rich qualitative feedback on how those values are currently lived (and how we could do better), and what behaviors we want to reinforce. The top values and Item A
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accompanying behavioral descriptions were brought back to departments for the second round of focus groups. These sessions asked for feedback on the proposed values: Do they resonate? Are the descriptions clear? How might they be lived in practice? Participants provided input on narrowing the list and refining language. Throughout the process, the Executive Leadership Team provided guidance, reviewed findings, encouraged department-level participation, and ensured alignment with our broader organizational goals. Noteworthy feedback from the engagement process included:
Employees across the organization consistently affirmed the importance of integrity, respect, innovation, and service excellence, while also signaling a strong desire for a culture that is more collaborative, inclusive, and adaptive. Many noted that our traditional values are sound, but the definition and language feel dated and do not fully reflect, for example, our increasing digital service delivery, remote/hybrid work arrangements, and continued emphasis on community trust and employee well-being.
Survey comments highlighted that “living our values” means not just words on the wall, but observable daily behaviors: how we treat colleagues, how we connect with residents, how we innovate responsibly and respectfully. A recurring theme was the importance of empowerment, both of employees and residents, to shape outcomes, solve problems, and deliver services in new, more responsive ways.

Recommended Values
The four values and descriptors that emerged from this review and engagement:
Respect
Exemplify integrity, courtesy, inclusion and professionalism Innovation
Develop creative solutions for continuous improvement
Service
Demonstrate excellence through purpose driven, collaborative problem solving Empowerment
Cultivate learning growth and shared success
These values emerged as clear, resonant, and representative of how our workforce wants to work and serve the Palo Alto community. Further, the values themselves create a short and catchy and word that would not only serve as an aspirational term, but a memorable acronym RISE, making it even more effective. Being able to Live our values means that the values are not only aspirational, but also relevant and reinforced in our everyday work.

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To make this tangible, a guide, and accompanying communications toolkit, of ideas for embedding the values into new staff onboarding, performance conversations, recognition programs and service delivery standards will soon be developed. A citywide employee recognition program designed around recognizing exemplary examples of these City values in action is also being finalized. A periodic check-in to assess how well the values are being integrated and refocus efforts as needed is also anticipated.

This project was only possible due to the efforts of everyone who participated: the organizational values team and focus group participants, all employees that completed the survey and provided feedback, and the Executive Leadership Team that provided ongoing support. These voices and engagement shaped a set of values that will strengthen our organization, guide our service to the public and support our culture of continuous improvement well into the future.

FISCAL/RESOURCE IMPACT
None

STAKEHOLDER ENGAGEMENT
The effort was led by a citywide Special Projects team represented by staff from the following departments and offices: Administrative Services, Community Services Department, Human Resources, Information Technology, Library, Planning and Development Services, Public Works, Utilities, Public Safety, Transportation, and Council Appointed Officers. A series of meetings and focus groups with the Executive Leadership Team and staff across the organization were held to gather input and facilitate discussions on organizational values. A citywide staff survey was also deployed to ensure everyone had an opportunity to participate. The results were shared organization-wide during the City Manager’s October all staff meeting.

ENVIRONMENTAL REVIEW
This informational report is not a project under the California Environmental Quality Act (CEQA).

ATTACHMENTS
None
APPROVED BY:

Ed Shikada, City Manager
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Palo Alto City CouncilDecember 8, 2025

Palo Alto City Council
December 8, 2025