From: Melissa Borgesi
To: Council, City
Cc: Jane Mark; Ana Ruiz; Susanna Chan
Subject: 12/8/25 City Council Meeting Agenda ITEM 15: REINTRODUCED FIRST READING: Adoption of an Ordinance Updating Palo Alto Municipal Code Section 18.40.250 (Lighting) Date: Monday, December 8, 2025 10:46:40 AM
Attachments: image001.png
Midpen Ltr_Palo Alto Lighting Ordinance 20251208.pdf
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Dear City Council Members and Staff,
Please find attached our agency’s comments regarding the draft ordinance updating the 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, which will be discussed at this evening’s City Council meeting.
Thank you for the opportunity to comment on this proposed ordinance language.
Sincerely,
Melissa
Melissa Borgesi
Planner III
Midpeninsula Regional Open Space District
5050 El Camino Real, Los Altos, CA 94022
(650) 625-6531 Direct
openspace.org
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D
ecember 8, 2025
City of Palo Alto City Council
City Hall
250 Hamilton Avenue
Palo Alto, CA 94301
SENT VIA E-MAIL TO: [email protected]
Subject: 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 D
ear Palo Alto City Council,
O
n behalf of the Midpeninsula Regional Open Space District (Midpen), we respectfully submit the following comments regarding the revised lighting ordinance.
Co
mprised of over 70,000 acres of acquired and protected open space on the San Francisco Peninsula, Midpen is one of the largest regional open space districts in California. Our mission is to acquire and preserve a regional greenbelt of open space land in perpetuity, protect and restore the natural environment, and provide opportunities for ecologically sensitive public enjoyment and education. Within the City of Palo Alto’s jurisdiction, Midpen owns and manages Monte Bello Open Space Preserve (Preserve).
M
idpen appreciates the City of Palo Alto utilizing “dark sky” principles in developing the lighting ordinance update, particularly in the areas that serve as wildlife refuge sites including creek and riparian corridors, large open spaces, and the Baylands. The clear guidance for light direction, intensity and color in the current ordinance draft will assist with protecting these sensitive resource areas. Midpen supports approval o f such an ordinance with consideration for any suggested revisions to improve the ordinance from a perspective of ecological value and benefit. We recognize that the City will rely on a community-based approach for compliance and commend the City’s efforts with developing educational and outreach materials to communicate the importance of protecting a “dark sky” and complying with wildlife light pollution protections standards.
T
hank you for the opportunity to comment on this ordinance revision. Should you have any questions about this letter, please contact me at (650) 625-6563 or via email at [email protected].
S
incerely,
J
ane F. Mark, AICP
Planning Manager
CC: Ana Ruiz, General Manager
Susanna Chan, Assistant General Manager
From: promiserani
To: Council, City
Subject: Support of Dark skies and induction cooking
Date: Sunday, December 7, 2025 9:04:54 PM
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Hi,
I am writing in support of the Dark skies ordinance in Palo Alto, and in support of induction cooking as well.
Dark skies are important for our quality of life, and for the health of our wildlife and children in our areas. In addition to saving energy with lower lighting, the efforts will reduce greenhouse gases, allowing better scientific observation of the night sky, the darker skies will allow for better navigation of birds, health of nocturnal animals, effects on plants, and improve sleep for humans of all ages.
Induction cooking is also important for Palo Alto to reach climate goals, improve indoor air quality, and reduce fossil fuel use, not to mention reduce overall energy use. The move toward total electrification will require this switch, and rebates and requirements will help hasten these positive changes.
Please vote in favor of both of these efforts for all Palo Altans.
Prerana Jayakumar
Midtown
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From: Tom Fountain
To: Council, City; Lauing, Ed; Cha, Kelly
Subject: Proposed Outdoor Lighting Ordinance
Date: Sunday, December 7, 2025 8:47:51 PM
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Dear Honorable Mayor and Members of the City Council,
With respect to the proposed lighting ordinance, I am writing to support the Edgewood Neighborhood Alliance’s position on the following:
I support the exemption of homes on the creek-side of Edgewood Drive given their unique circumstances, including encampments in the creek, crime and quality of life issues, and access from East Palo Alto which lacks barriers to creek entry. There is a well-documented threat to health and safety of residents that demands this reasonable exemption. The health and safety of residents must take priority.
The exemption for Edgewood properties contains a drafting error and, consistent with Staff's recommendation, should be corrected to the following:
“(7) Single family residential sites adjacent to San Francisquito Creek and fronting on Edgewood Drive if the portion of the site subject to a permanent easement in favor of the Santa Clara Valley Water District (or its successor in interest) for flood control purposes is reconfigured after January 1, 2002. These sites shall be subject to the requirements under Section 18.40.250(e)(4)(A).” More generally, I oppose the proposed ordinance. I hereby incorporate by reference my prior objections expressed in writing to the City Council, the Planning & Transportation Commission (PTC), and city staff.
Most notably, the proposed ordinance should not require retrofit to existing residences. It is telling when even the proposal's advocates -- including the Sierra Club and the American Bird Conservancy -- believe this proposed ordinance goes too far. The cost and environmental waste produced by this poorly considered ordinance more than offsets the stated environmental benefits.
Additionally, this ordinance fails to adequately establish the relationship between the new regulation and the proven benefit. The proposed ordinance imposes an unreasonably high burden on existing residences. In many cases it requires homeowners to replace entire fixtures, not just bulbs. As but one example, the estimated cost to bring my property into compliance is $210,000 between new light fixtures and having to replace custom cuts of stone, siding, and other materials upon which these fixtures are mounted. Based on the opposition from Stanford University, Stanford hospital, and the many businesses who participated in the workshop, it is clear the cost is similarly high for commercial enterprises. We should find solutions to reduce housing costs and promote local businesses, not drive up cost by requiring retrofit construction.
Finally, there are many problematic issues with this proposed ordinance and its retrofit application. The City Council is misguided in stating this is “only” a future cost; every Palo Alto homeowner selling their property must now disclose this future cost to potential buyers.
The City’s inability (and stated intent not) to enforce this code only serves to further pit neighbors against one another in a community that is already too acrimonious; City Council should use guidelines and incentives rather than criminalize lighting. There are many other similar technical issues with the proposed code applied to existing residence; it is disheartening that after months, staff has still not addressed even a single shortcoming. For example, dimming is not a permitted solution to make an existing fixture and luminaire comply. It leads me to conclude this is entirely performatory and not at all about actually improving the lives of Palo Alto residents.
I strongly urge City Council take a more measured and practical approach to advancing this environmental goal. First, these changes should only be applied to new construction and not retroactively applied to existing residences. If existing properties must be covered, then limits should be expressed in lux rather than lumen.
The current proposed ordinance due to the retrofit requirement fails to balance property owner cost with the claimed benefits, creates unreasonable expense for homeowners, causes environmental harm from the premature replacement of fixtures and related construction, and fails to apply even practical solutions such as dimming to lighting issues. As a resident of Palo Alto, I respectfully encourage City Council to send the ordinance back to Staff to better address these issues.
Sincerely,
Tom Fountain
Palo Alto resident
From: Kristin Sato
To: Council, City; Lauing, Ed; Cha, Kelly
Subject: Proposed Outdoor Lighting Ordinance
Date: Sunday, December 7, 2025 6:26:14 PM
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Palo Alto City Council, [email protected] Ed Lauing, [email protected]
Re: Proposed Outdoor Lighting Ordinance
Dear Honorable Mayor and Members of the City Council,
With respect to the proposed lighting ordinance, I am writing in support of the Edgewood Neighborhood Alliance and the following:
I fully support the exemption of homes on the creek-side of Edgewood Drive given their unique circumstances, including encampments in the creek, crime and proximity to East Palo Alto, which has no barriers to enter the creek.
The exemption for Edgewood properties contains an error and should be corrected to the following:
“(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).”
Last, I oppose this lighting ordinance be applied retroactively. If this lighting ordinance must be passed, it should only apply to new construction.
Thank you.
Sincerely,
Kristin Sato
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From: herb
To: Council, City; Clerk, City
Subject: December 8, 2025 City Council Meeting, Agenda Item #15: Outdoor Lighting Restrictions Date: Sunday, December 7, 2025 3:06:54 PM
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DECEMBER 8, 2025 CITY COUNCIL MEETING
AGENDA ITEM #15: OUTDOOR LIGHTING RESTRICTIONS
The public letters in this meeting's agenda packet for this agenda item include only those public letters that were included in the agenda packet for the November 10, 2025 meeting, but omit letters received after that agenda packet was distributed.
Reproduced below is the letter I sent you for the November 10, 2025 meeting regarding light pollution from unshielded LED street lights.
Packet Page 300 of the current agenda packet shows the effect that shielding LED street lights has on decreasing light pollution.
An example of the light pollution from unshielded LED street lights can be seen from the LED street light in front of the Children's Library on Harriet Street that is at the end of the library that is furthest from Hopkins Avenue and lights up the intersection of Harriet Street and Hopkins Avenue.
Residences across the street from the Children's Library are closer to the unshielded light than the distance from that light to Hopkins Avenue. I wonder if anyone who lives across the street from that LED street light is bothered by its unshielded light.
Thank you for your consideration of these comments.
Herb Borock
NOVEMBER 10, 2025 CITY COUNCIL MEETING
AGENDA ITEM #8: OUTDOOR LIGHTING REGULATIONS
Unshielded LED Street Lights appear to be the main cause of light pollution that I notice in the areas of the city that I walk in when in appears to be daytime instead of night when there is no light from either the sun or the moon, but the City's LED Street Lights are not covered by this proposed Ordinance.
Staff first implemented the conversion of High Pressure Sodium street lights to LED street lights as a pilot project, and then obtained City Council approval to install the LED street lights in phases. (See https://www.cityofpaloalto.org/files/assets/public/v/1/library/news/led- streetlight-conversion-project-map.pdf.)
At first it appears that staff did the conversion, but the most recent areas of the City were converted by contract. (See staff report #4116 at https://www.cityofpaloalto.org/files/assets/public/v/1/agendas- minutes-reports/reports/city-manager-reports-cmrs/year- archive/2013/final-staff-report-id-4116_led-street-lights-supply-and- installation.pdf.)
The Bid Summary Sheet at page 5 of that staff report indicates that only 100 house-side shields and 100 cul-de-sac-side shields were to be removed as part of that contract, which implies that for the most part shields remained, but I haven't had the opportunity to walk at night through the areas of the city covered by the contract.
When I walk at night on the 1100 block of Waverley Street between Lincoln Avenue and Kingsley Avenue, the street lights on one side of the street light up the sidewalk on the other side of the street.
Tonight Sunday, November 9, there will be a period of time between Astronomical Twilight (about 6:30 pm) when there is no light from the sun, and Moonrise (about 9:30 pm) when there is no light from the moon.
If you have an opportunity to walk on the 1100 block of Waverley at that time, check to see if the sky is dark and you can see the stars, and walk on the side of the street opposite the side with the LED Street Lights to see if the sidewalk is dark or light.
You need to know the Color Temperature of those LED Street Lights that might be different for different manufacturers.
Thank you for your consideration of these comments.
Herb Borock
From: Pria Graves
To: Council, City
Subject: Lighting Ordinance Update
Date: Sunday, December 7, 2025 12:04:11 PM
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Dear Council Members,
I am writing to encourage you to support the proposed update to the lighting ordinance to be consistent with the Dark Sky principles.
Humans and all other animals do better when not subjected to bright lighting at night. Migrating birds and nocturnal wildlife are especially vulnerable. A darker night sky would also allow us to once again enjoy a view of the stars! In addition to lighting around homes, it would be extremely helpful if we could “fix” the athletic facility lighting! The field at Page Mill and El Camino sends light to my home several blocks away. And the lighting of sports fields on the Stanford Campus makes driving toward El Camino difficult at night. The light “poles” also ruin the view of the Hoover Tower even in the day time! Horrific.
I’ve lived here for 40 years and each year our surroundings, street lights and other sources, get brighter and brighter.
Thank you for your support.
Regards,
Pria Graves
2130 Yale Street
From: Jennifer Landesmann
To: Council, City
Subject: Night time ordinance
Date: Saturday, December 6, 2025 4:28:44 PM
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Dear Council,
The City's staff report for Monday has a recommendation to "adopt new outdoor lighting regulations..in order to increase the health and well-being of Palo Alto residents, protect wildlife and natural ecosystems, and reduce light pollution." Conservation of energy and beautifying the night sky are listed among the advantages of the ordinance. And some key health issues:
the body’s natural circadian rhythm, promoting better sleep improving safety and comfort at night.
Research about negative impacts on people, species, and the natural environment in fact are about the importance of the timeframe (night time). I would suggest that the City begin to consider a broader approach where various initiatives fit with respect to nighttime protection. Certainly the cumulative effects of noise and light pollution are an issue. Here is a scary thought - Unignorable Flying Billboards at 250 feet.
I support that the City give "nighttime" the importance that it should have for the promotion of the health of humans and the natural environment. To abate the various types of pollution during this timeframe - and in a world that has become 24/7.
Jennifer
From: Ailsa Ludvik
To: Council, City
Subject: December 8, 2025 Agenda item 8: please STOP this terrible idea....say NO Date: Saturday, December 6, 2025 4:15:03 PM
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To the Palo Alto City Council
Please vote NO on this notion of 'dark skies'.
Lights at night are NOT light pollution, lights at night time are a miracle and keep people safe.
Please concentrate on things that will improve living in Palo alto, and stop encroaching into our lives with scary notions of dying from night time lights ! Fix University Ave, it's dismel and dirty....repair the roads....trim the City trees.....leave our night lights alone.
thank you
Ailsa Ludvik
Palo Alto
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From: kip husty
To: Council, City
Subject: Dark Sky Ordinance
Date: Friday, December 5, 2025 10:40:51 PM
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Dear Council Members,
My wife, Anne, and I have lived in the Seale Park neighborhood for over 25 years, and have lived in Palo Alto for nearly 50 years (three years in the Woodland neighborhood). Both of us, as well as our daughter, coveted the rare dark skies that we could find could find in empty lots (a thing of the past) and parks. The street lighting was too obtrusive for us, barring any aesthetically pleasing sense of dark skies with stars. The conditions for dark skies has gotten worse over the years, and now my neighborhood park, Seale Park, has installed a noticeably more offensive light (I believe it is an LED light). The field where we could go on walks and stand gazing into darkness now has a light so bright at one end that shadows are cast over 50 yards away! The santuary of darkness that we once enjoyed has been destroyed. Coupled with the obnoxious brightness of a bulb that irritates the eyes as they dilate in the semi-dark, we have not heard the night 'birds' that I used to hear and see flying over the field (I don't know what they were, they might have even been bats) when a sodium vapor light was in this spot. It was bad, but it was far more confined.
We understand the fear of the dark, but it is not very rational. We have seen people in the park two or three times in thousands of late night walks to the field (when we were younger, it was a near nightly activity, now it is mostly me by myself. Crime is a problem, but late night break-ins are a small share of the crime. While violence is a potential, it is not a rampant crime in this city; we feared skunks much more than an assault. Additionally, we all should note that so-called 'white-collar' has a far greater cost to society than burglary, yet fighting 'white-collar' crime occupies tiny fractions of the law enforcement time and resources, and does not place environmental and beauty destroying measures. Further, economic inequality far and away over-shadows darkness as a precursor to crime. We do not expect Palo Alto government to prioritize rooting out these latter ills that are more relevant to the problem of crime than lighting the skies, but we do expect the city to protect the quality of life and the natural environment that has made Palo Alto such a desirable community to call home.
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Please, support and pass the Dark Sky (Outdoor Lighting) Ordinance and give us back the night. Anne and I do not fear the dark, we do, however, find fault with a city that blindly throws ugly and damaging solutions having little to no significant function other than to placate ungrounded and exaggerated fears.
Thank you,
Kip and Anne Husty
922 Bautista Ct.
Palo Alto, CA, 94303
From: Jeff Levinsky
To: Council, City
Subject: Monday"s Agenda Item 15: Please Vote for a Strong Dark Sky Ordinance Date: Friday, December 5, 2025 6:06:04 PM
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Dear City Council members:
I agree with the Sierra Club and Bird Alliance that we need to strengthen our dark sky ordinance. Having worked and lived in Palo Alto for many decades, I’ve seen much energy spent to improve our town for human beings. Let’s also consider how we impact other species. There are easy steps we can take to protect birds, such as:
· Require nonessential outdoor lighting be off by 11 PM, rather than midnight
· Have new buildings, remodels, and fixture replacements meet compliant lighting standards
· Prohibit blinking/flashing/rotating lights, searchlights, aerial lasers, and spotlights citywide
·
Insist that existing adjustable lighting comply within one year of the ordinance going into effect
None of these are onerous. Please consider that as neighboring cities pass such laws, we need to as well to create a region-wide nightly dark area that’s better for birds and our environment. We always want to be the bright spot, but in this case we should go dark.
Thank you,
Jeff Levinsky
From: Pat Markevitch
To: Council, City
Subject: Outdoor Lighting Ordinance Agenda Item 15
Date: Friday, December 5, 2025 5:49:42 PM
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Honorable City Council members,
I am in favor of the proposed out5door lighting ordinance.
I served the Parks and Recreation Commission for over 10 years so I am very aware of the dangers to birds when it comes to artificial light.
My personal experience with overly bright artificial light is ongoing.
The apartment building behind me, on the corner of Hawthorne and Ramona underwent a renovation. As a result, the back area of the complex has these lights that are so bright that if you were to look at them for more than a second, your eyes will become physically pained. It's like looking at the Sun.
I need fresh air to sleep so my shades need to be pulled up. As a result, the lights from their yard literally spotlights my bed so I have to build a pillow wall to keep the lights from shining in my eyes.
I have no idea who to contact. All they need to do is lower the brightness, aim the lights down into the yard and put the lights on motion detectors.
Thank you
Pat Markevitch
From: Melanie Grondel
To: Council, City
Subject: Dark Sky !!
Date: Friday, December 5, 2025 2:34:17 PM
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Dear Council Members,
The migrating birds have been a great concern for many years. They are encountering significant and increasing risks on their migration routes in particular at night when they need a dark sky for their migration navigation .
The birds are an essential part of our eco system and provide joy for our spirit as they are the most frequent wildlife that we encounter in the city.
We value our trees, we protect our wetlands, it is high time that we protect the birds. They are in serious decline !
29% of migrating birds are gone and one third of the birds are under conservation concern in the US and Canada (Cornell Labs) .
Our trees and parks and gardens are unthinkable without birds .
They are our friends and need protection now !
I am ready to take some extra care and apply the Dark Sky Ordinance to my environment and I hope that my fellow Palo Altans are ready to do the same.
Let’s protect the birds like we protect our trees.
I am asking the City Council to fully support the Dark Sky Ordinance.
Thank you for your consideration.
Melanie Grondel - College Terrace.
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From: Meri Gruber
To: Council, City
Subject: Opposition to Proposed Dark Sky Ordinance - Agenda Item 15 Date: Friday, December 5, 2025 11:05:54 AM
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Dear City Council Members,
I urge you to reject the proposed outdoor lighting ordinance for the following reasons:
Safety First: Well-lit streets reduce pedestrian fatalities by 30-50%. The mandatory midnight curfew creates genuine safety risks for residents returning home late, taking out trash, or responding to emergencies. There is an exemption for Edgewood Drive based on security perceptions. If security lighting matters there, it matters everywhere.
Unenforceable Law: Staff explicitly states the city "does not have sufficient resources to proactively enforce the ordinance." Creating laws that cannot be enforced breeds selective enforcement and neighbor disputes.
Disproportionate Costs: Requiring all existing lighting to comply imposes enormous costs on homeowners and businesses. No cost-benefit analysis justifies this burden.
Missing Evidence: The ordinance provides no baseline data on current light pollution levels, no quantified wildlife harm, and no comparison of less restrictive alternatives.
Good environmental policy balances goals with practicality. This ordinance sacrifices safety, imposes massive costs, and creates laws the city cannot enforce—all without demonstrated local necessity.
Please vote no.
Thank you for your service to our community.
Best regards,
Meri Gruber
Palo Alto
From: Catherine Cohen
To: Council, City
Subject: December 8, 2025 Agenda item 8: i strongly oppose a strong outdoor lighting ordinance Date: Friday, December 5, 2025 10:51:53 AM
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Hi, my name is Catherine Cohen. I have been born and raised in Palo Alto.
I am strongly against the outdoor lighting ordinance that you are proposing. I have dogs and do not have a yard and often have to take them out in the middle of the night. I only feel safe because of the lights that guide my way in the darkness. I also fear that even with the coyote issues we’re having now that will intensify with less light and also cause a safety concern.
I also feel that having less lights is just opening the door for more crime in Palo Alto. Something we’re already struggling with. Car break-ins. House break-ins.
I believe we could solve the light issue by maybe asking residence to install lights that point down versus pointing out or up but going into a darkness is not an option in my opinion.
Thank you
Sent from my iPhone
Please excuse typos
From: Jo Ann Mandinach
To: Council, City
Subject: Subject: 12/8/25 Agenda Item 15: We need a strong outdoor lighting ordinance Date: Friday, December 5, 2025 8:57:22 AM
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Dear Mayor & City Council,
Please adopt the Dark Sky (Outdoor Lighting) Ordinance and instruct the city to everything possible to publicize this.
Why do I care?
Because two separate properties directly behind me were sold this past year and both new owners have extremely bright lights shining into their backyards -- AND into mine -- all night.
One has a particularly bright and glaring spotlight that's aimed high enough to be extremely annoying.
As more and more of us trim trees and bushes due to fire insurance requirements, these extremely bright lights become more problematic.
Thanks for your consideration.
Jo Ann Mandinach
Palo Alto, CA 94301
From: GreenSpacesMV
To: Council, City
Subject: Support for a Strong Palo Alto Dark Sky Ordinance (Agenda Item 15 on 12/8 Agenda) Date: Friday, December 5, 2025 8:21:41 AM
Attachments: GSMV letter to PA - Dark Sky.pdf
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Hello,
Please see the attached comment letter in support of a Strong Dark Sky Ordinance in Palo Alto.
Thank you for your time,
Silja Paymer
GreenSpacesMV
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December 5
rd
, 2025
Re: Support for a Strong Palo Alto Dark Sky Ordinance (Agenda Item 15 on 12/8 Agenda) Dear Mayor Lauing and Palo Alto Councilmembers,
GreenSpacesMV is a volunteer-based community group advocating for parks, trees, biodiversity,
climate
resilience,
and
nature-forward
planning
in
Mountain
View.
Our
members
have
been
deeply
engaged
in
advancing
responsible
lighting
practices
in
our
own
city,
including
early
outreach
and
policy
recommendations
that
helped
initiate
Mountain
View’s
upcoming
citywide
Dark
Sky
Ordinance
process.
As neighbors who share the night sky, and are impacted by light that crosses city borders, we strongly
support
the
recommendations
submitted
by
the
Sierra
Club
Loma
Prieta
Chapter
and
the
Santa
Clara
Valley
Bird
Alliance.
In
particular,
we
urge
Palo
Alto
to:
● Require all nonessential outdoor lighting to be turned off by 11:00 PM with reasonable
exceptions,
rather
than
midnight.
● Require all new buildings, remodels, and fixture replacements to meet compliant lighting
standards.
● Apply the prohibition on blinking, flashing, rotating lights, as well as searchlights, aerial
lasers,
and
spotlights,
citywide,
including
Edgewood.
● Require existing adjustable lighting to be compliant within one year of the effective
date
of
the
ordinance.
Mountain View has recently launched community engagement for our own Dark Sky Ordinance, with
public
updates
and
materials
available
at
MountainView.gov/DarkSky
.
As
neighboring
cities
working
toward
regional
ecological
and
climate
resilience
we
hope
Palo
Alto
will
adopt
a
strong
ordinance
that
sets
an
example
for
other
jurisdictions
in
the
Midpeninsula.
Thank you for your leadership in reducing light pollution and protecting our shared night sky.
Sincerely,
Silja Paymer for
GreenSpacesMV
From: Lauren Swezey
To: Council, City
Subject: In favor of Outdoor Lighting Ordinance
Date: Thursday, December 4, 2025 10:14:41 PM
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Dear Council Members,
My name is Lauren Bonar Swezey. I am a lifelong resident of Palo Alto and have lived near the San Francisquito Creek for many years.
I’ve always considered Palo Alto a special place, especially because of its lush tree canopy and the endemic and migratory birds that visit the trees and gardens here.
Birds are constantly at risk in a city environment due to outdoor lighting. It disorients them and disrupts migration. When I worked at Facebook/Meta on the Frank Gehry-designed buildings, we installed bird-friendly windows and directed all lighting to face downward. We also dimmed lights at night and adhered to Lights Out Campaigns during migration periods.
The Palo Alto City Council must protect these special visitors by passing the outdoor lighting ordinance.
Thank you for your support,
Lauren Bonar Swezey
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From: Dashiell Leeds
To: Council, City; Burt, Patrick; Lauing, Ed; Lu, George; Lythcott-Haims, Julie; Reckdahl, Keith; Stone, Greer; Veenker, Vicki
Cc: [email protected]; Clerk, City; Cha, Kelly; James Eggers; Mike Ferreira; Gita Dev; Barbara Muir; Wils Cain
Subject: SCLP and SCVBA re December 8 Agenda Item 15 - Dark Sky (Outdoor Lighting) Ordinance Date: Thursday, December 4, 2025 6:58:22 PM
Attachments: SCLP SCVBA Letter to Palo Alto re Dec 8 Dark Sky Ordinance.pdf SCLP SCVBA Redlined Version of Palo Alto Draft Dark Sky Ordinance.pdf CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.
Dear Mayor Lauing and Palo Alto City Councilmembers,
The Santa Clara Valley Bird Alliance and the Sierra Club Loma Prieta Chapter support the adoption of Palo Alto’s Dark Sky (Outdoor Lighting) Ordinance, and suggest a few critical corrections. We appreciate the extensive work by City staff, and the clear direction from the Planning and Transportation Commission and Council to develop a measure that protects migratory birds, nocturnal wildlife, and human health while conserving energy and restoring the City’s night sky.
The ordinance follows best practices from DarkSky International and the Illuminating Engineering Society by ensuring that lighting is shielded, directed, and used only where and when needed. Please consider incorporating the five requests listed in the attached letter. We have also attached a redlined version of the ordinance showing our suggested changes.
Sincerely,
Shani Kleinhaus
Environmental Advocate
Santa Clara Valley Bird Alliance
Dashiell Leeds
Conservation Coordinator
Sierra Club Loma Prieta Chapter
SAN MATEO, SANTA CLARA & SAN BENITO COUNTIES
December 4, 2025 Palo Alto City Council 250 Hamilton Ave Palo Alto, CA 94301 Re: December 8 Agenda Item 15 - Dark Sky (Outdoor Lighting) Ordinance Dear Mayor Lauing and Palo Alto City Councilmembers, The Santa Clara Valley Bird Alliance and the Sierra Club Loma Prieta Chapter support the adoption
of
Palo
Alto’s
Dark
Sky
(Outdoor
Lighting)
Ordinance,
and
suggest
a
few
critical
corrections.
We
appreciate
the
extensive
work
by
City
staff,
and
the
clear
direction
from
the
Planning
and
Transportation
Commission
and
Council
to
develop
a
measure
that
protects
migratory
birds,
nocturnal
wildlife,
and
human
health
while
conserving
energy
and
restoring
the
City’s
night
sky.
The ordinance follows best practices from DarkSky International and the Illuminating Engineering
Society
by
ensuring
that
lighting
is
shielded,
directed,
and
used
only
where
and
when
needed.
Please
consider
incorporating
the
following
five
requests.
We
have
made
changes in blue since our November 10th letter to the City Council on this subject. ● Amend Sections 18.40.250(d)(4) and 18.40.250(e)(4)(A) to adjust the curfew start time from
12 a.m.
to
11 p.m.
● Amend Section 18.40.250(c)(3) to remove the phrase “If a building permit is required” to
apply
the
ordinance
to
all
new
installation,
replacement,
or
modification
of
outdoor
luminaires,
● Amend Section 18.40.250(d)(7) to ensure that prohibited lighting types are not allowed in the
exempted
Edgewood
Drive
properties,
● Remove 18.40.250(L)(2)(A)(B) and (3), removing retrofit requirements for existing outdoor
lighting,
and
● Retain and shorten the compliance period in Section 18.40.250(L)(1) for easily adjustable existing
lighting
fixtures
to
one
year.
Request #1
Amend Sections 18.40.250(d)(4) and 18.40.250(e)(4)(A) to adjust the curfew start time from 12 a.m.
to
11 p.m
Current text
Section 18.40.250 (d) Exemptions . The following types of lighting are exempt from the lighting
requirements
of
the
section:
(4) Seasonal lighting, subject to extinguishment at 12:00 a.m., during the period of
October
15 through
January
15 of
each
year;
Section 18.40.250 (e) Lighting Standards . (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.
Proposed Text
Section 18.40.250 (d) Exemptions . The following types of lighting are exempt from the lighting
requirements
of
the
section:
(4) Seasonal lighting, subject to extinguishment at 11:00 p.m. 12:00 a.m., during the
period
of
October
15 through
January
15 of
each
year;
Section 18.40.250 (e) Lighting Standards . (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
11:00 p.m. 12:00 a.m.,
two
hours
after
the
close
of
business,
or
when
people
are
no
longer
present
in
exterior
areas,
whichever
is
later.
Justification
The Lighting Curfew standards in this ordinance are incredibly flexible, allowing for lights to remain
on
two
hours
after
the
close
of
business
or
when
people
are
no
longer
present
in
exterior
areas,
whichever
is
later.
Adjusting
the
start
time
of
the
curfew
will
not
affect
luminaires
that
remain
illuminated
at
late
hours
for
those
reasons.
Adjusting
the
curfew
start
time
one
hour
earlier,
to
11:00
p.m.
will
allow
the
ordinance
to
maximize
its
light
pollution
reduction
at
key
nighttime hours while retaining the flexibility to allow residents and businesses to operate normally.
Furthermore, the 11:00 p.m. time would correspond with the curfews of many other adopted ordinances,
such
as
those
in
Cupertino,
Malibu,
and
Los
Altos,
which
all
use
11pm
residential
curfews.
Brisbane
and
Rancho
Palos
Verdes
contain
curfews
which,
at
the
latest,
begin
at
10 p.m.
Request #2
Amend Section 18.40.250(c)(3) to remove the phrase “If a building permit is required” to apply
the
ordinance
to
all
new
installation,
replacement,
or
modification
of
outdoor
luminaires.
Current text
(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.
Proposed Text
(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.
Justification
Both the Planning and Transportation Commission (October 30, 2024) and the City Council (April
7,
2025)
explicitly
directed
that
the
lighting
standards
apply
to
all
new
and
replacement
outdoor lighting. The April 7th City Council minutes 1 and the staff report for Item 8 confirm this directive, yet the draft ordinance retains the inconsistent “building permit” qualifier.
Limiting applicability to projects requiring a building permit creates a major loophole that exempts
most
fixture
replacements
and
new
lighting
installations.
Since
lighting
installations
do
not
typically
require
permits,
much
new
and
replacement
lighting
would
remain
unregulated.
Removing
the
“building
permit”
qualifier
will
bring
the
ordinance
into
alignment
with
Council
direction
and
ensure
it
functions
as
intended.
Request #3 Amend Section 18.40.250(d)(7) to ensure that prohibited lighting types are not allowed in the
exempted
Edgewood
Drive
properties.
1 https://cityofpaloalto.primegov.com/Public/CompiledDocument?meetingTemplateId=16025&compileOutpu tType=1
Current Text
“(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).”
Proposed Text
(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
Sections
18.40.250(e)(4)(A)
and 18.40.250(g) .
Justification While we appreciate that Section 18.40.250(e)(4)(A) applies the lighting curfew, the exemption in
(d)(7)
inadvertently
allows
the
use
of
prohibited
lighting
such
as
blinking,
flashing,
or
rotating
lights,
and
searchlights,
aerial
lasers,
or
spotlights,
all
forms
of
illumination
that
are
unnecessary
for
safety
and
highly
disruptive
to
wildlife.
Safety
can
be
achieved
using
fully
shielded,
dark-sky-compliant
luminaires.
Extending
the
prohibited
lighting
clause
to
this
area
will
prevent
excessive
glare
and
protect
one
of
Palo
Alto’s
most
sensitive
riparian
corridors
along
San
Francisquito
Creek.
Request #4
Remove 18.40.250(L)(2)(A)(B) and (3), removing retrofit requirements for existing outdoor lighting
Current Text (Section 18.40.250(L)
“(L) Existing Nonconforming Lighting (1) Within two years of [the effective date of this ordinance]: Where existing outdoor luminaires
have
the
ability
to
adjust
(through
existing
dimmers,
directional
adjustability,
timers,
etc.),
the
requirements
under
Section
18.40.140(e),
except
for
the
shielding
requirements
under
subsection
18.40.140(e)(1),
shall
apply.
(2) For all existing outdoor luminaires, the requirements under Section 18.40.140(e) shall apply
within
the
following
timeframes
from
[the
effective
date
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.
Proposed Revision
Keep (L)(1) to retain the requirement that all easily-adjustable luminaires be adjusted to be
compliant
with
the
ordinance.
We
recommend
adjusting
the
timing
window
of
(l)(1),
as
described
below
in
Request
#4.
Delete subsections (L)(2)(A) and (B) and (3), removing the retrofit schedule. (2) For all existing outdoor luminaires, the requirements under Section 18.40.140(e) shall apply
within
the
following
timeframes
from
[the
effective
date
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.
Justification
Requiring retrofits for all existing lighting could be difficult to administer and monitor, and can create
hardship
for
residents
and
businesses.
Applying
the
ordinance
to
all
new,
replacement,
and
easily-modified
lighting
would
achieve
gradual
citywide
compliance
through
equipment
turnover
while
avoiding
confusion
and
unnecessary
administrative
burden.
Retaining the hardship exemption (Section 18.40.250(j)) and clear applicability to all new and replacement
lighting
ensures
that
future
installations
meet
dark-sky
standards
without
imposing
mandatory
retrofits
on
existing
luminaires.
Request #5
Retain and shorten the compliance period in Section 18.40.250(L)(1) for easily adjustable existing
lighting
fixtures
to
one
year
Current Text (Section 18.40.250(L)(1))
“(1) Within two years of [the effective date of this ordinance]: Where existing outdoor
luminaires
have
the
ability
to
adjust
(through
existing
dimmers,
directional
adjustability,
timers,
etc.),
the
requirements
under
Section
18.40.140(e),
except
for
the
shielding
requirements
under
subsection
18.40.140(e)(1),
shall
apply.”
Proposed Text
“(1) Within one year 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
subsection
18.40.140(e)(1),
shall
apply.”
Justification
A two-year grace period is unnecessarily long for fixtures that can be corrected through simple adjustments
such
as
dimming,
re-aiming,
or
resetting
timers.
Comparable
Dark
Sky
ordinances,
including
Brisbane’s,
require
compliance
within
one
year.
A
one
year
window
provides
sufficient
time
for
the
City
to
distribute
educational
materials
and
for
property
owners
to
make
straightforward
adjustments,
achieving
measurable
reductions
in
light
pollution
much
sooner.
In Conclusion With the brief but critically important modifications we have suggested, Palo Alto’s dark sky ordinance
will
reduce
light
pollution
over
time
and
improve
public
health
and
public
safety
and
protect
migratory
birds
and
wildlife.
The
provisions
of
this
ordinance
are
in
line
with
successfully
adopted
dark
sky
ordinances
throughout
the
nation.
The
requirements
are
extremely
flexible,
ensuring
that
business
in
Palo
Alto
will
not
be
impeded,
and
are
robust
enough
to
protect
residents
and
wildlife
from
the
dangers
of
over-lighting.
Please
move
to
adopt
this
ordinance,
with
the
modifications
we
have
suggested.
Sincerely,
Shani Kleinhaus Environmental Advocate Santa Clara Valley Bird Alliance Dashiell Leeds Conservation Coordinator Sierra Club Loma Prieta Chapter
Note from SCLP and SCVBA: The text we recommend removing will be colored red and struck through,
and
the text we recommend adding will be colored blue. All other non-colored strikethroughs
are
those
originally
proposed
by
staff.
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
nighƫme
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.
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.
(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 11:00 p.m. 12:00 a.m., during the period
of
October
15 through
January
15 of
each
year;
(5) Lighting for Airport Operations. Nothing in this section shall be interpreted to restrict, limit,
or
otherwise
regulate
lighting
that,
in
the
reasonable
judgment
of
the
Airport
Manager,
is
prudent
or
necessary
for
airport
operations,
airport
safety,
or
air
navigation
in
connection
with
operations
at
the
Palo
Alto
Municipal
Airport;
or
(6) Lighting for Emergency Shelters. Lighting for emergency shelters shall be subject to PAMC
18.14.060.
(7) Single family residential sites adjacent to San Francisquito Creek and fronting on Edgewood
Drive
if
the
portion
of
the
site
subject
to
a
permanent
easement
in
favor
of
the
Santa
Clara
Valley
Water
District
(or
its
successor
in
interest)
for
flood
control
purposes
is
reconfigured
after
January
1,
2002.
These
sites
shall
be
subject
to
the
requirements
under
Section
18.40.250(e)(4)(A) and 18.40.250(g). (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.
(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
11:00 p.m. 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,
NVR1,
or
NV-R2.
(A) When abutting any residential use, no spillover of lighting to adjacent properties
shall
be
allowed.
(B) A maximum of 1,260 lumens shall be allowed for each fully shielded outdoor lighting.
No
more
than
420
lumens
shall
be
allowed
for
permitted
non-shielded
outdoor
lighting.
(C) Skylights shall limit illuminance and glare during night hours. Glare shall be mitigated
through
the
use
of
translucent
glass,
shading
systems,
and
interior
light
placement.
Skylights
shall
not
use
white
glass.
(D) Height for Recreational and Security Lighting. Free-standing lighting shall be a
maximum
of
twelve
feet
(12’)
in
height
for
those
that
were
installed
on
or
after
March
11,
1991.
(2) Athletic Facilities Lighting. Outdoor athletic facilities shall conform to the following standards:
(A) Field lighting is provided exclusively for illumination of the surface of play and viewing
stands,
and
adjacent
proximity
areas
for
public
safety.
(B) Illumination levels shall be adjustable based on the task (e.g., active play vs. field
maintenance).
(C) Off-site impacts of the lighting will be limited to the greatest practical extent possible.
(D) Lights shall be extinguished by 10:30 p.m. except when the facilities are being
used
for
active
play
and
maintenance
before
or
after
permitted
events,
and
the
lights
are
equipped
with
a
timer.
(E) Timers that automatically extinguish lights shall be installed to prevent lights being
left
on
accidentally
overnight.
(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 footcandle
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.
(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 . Public Facilities, including City-owned and operated facilities, shall comply with
the
outdoor
lighting
standards
of
this
Section
to
the
extent
feasible.
The
Director
may
grant
adjustments
to
any
applicable
lighting
standards
for
such
facilities
if
the
adjustment
is
necessary
for
the
efficient
operation,
maintenance,
or
safety
of
the
facility,
or
to
ensure
public
safety
and
security;
and
is
consistent
with
the
overall
intent
and
purpose
of
this
Section.
A
written
request
for
an
adjustment,
including
supporting
documentation,
shall
be
submitted
and
shall
be
reviewed
according
to
the
applicable
review
procedures
in
PAMC
Section
18.77 associated
with
the
proposed
development.
(l) Existing Nonconforming Lighting . (1) Within two years one year of [the effective date of this ordinance]: Where existing outdoor
luminaires
have
the
ability
to
adjust
(through
existing
dimmers,
directional
adjustability,
timers,
etc.),
the
requirements
under
Section
18.40.140(e),
except
for
the
shielding
requirements
under
the
subsection
18.40.140(e)(1),
shall
apply.
(2) For all existing outdoor luminaires, the requirements under Section 18.40.140(e) shall apply
within
the
following
timeframes
from
[the
effective
date
of
this
ordinance]:
(A) Residential and Mixed Use Zoning Districts: Within ten years. (B) Nonresidential Zoning Districts: Within five years. (3) Any nonconforming lighting still in place after the compliance deadline shall remain extinguished
at
all
times
until
they
are
brought
into
compliance.
SECTION 3. Subsection (e) of Section 18.40.230 (Rooftop Gardens) of Chapter 18.40 (General Standards
and
Exceptions)
of
Title
18 (Zoning)
of
the
Palo
Alto
Municipal
Code
is
amended
to
read
as
follows
(additions
underlined
;
deletions
struck-through
):
(e) Any lighting shall be shielded from public views and have full cutoff fixtures that cast downward-facing
light,
or
consist
of
low-level
string
lights;
no
up-lighting
is
permitted.
Lights
shall
be
dimmable
to
control
glare
and
placed
on
timers
to
turn
off
after
10:00
p.m.
Photometric
diagrams
must
be
submitted
by
the
applicant
to
ensure
there
are
no
spillover
impacts
into
windows
or
openings
of
adjacent
properties.
For
lighting
requirements,
refer
to
Section
18.40.250
.
SECTION 4. Subsection (g) of Section 18.10.040 (Development Standards) of Chapter 18.10 (Low
Density
Residential
(RE,
R-2
and
RMD)
Districts)
of
Title
18 (Zoning)
of
the
Palo
Alto
Municipal
Code
is
amended
to
read
as
follows
(additions
underlined
;
deletions
struck-through
):
(g) Lighting in R-2 District In the R-2 district, recreational and security lighting shall be permitted only so long as the lighting
is
shielded
so
that
the
direct
light
does
not
extend
beyond
the
property
where
it
is
located.
Free-
standing
recreational
and
security
lighting
installed
on
or
later
than
March
11,
1991,
shall
be
restricted
to
twelve
feet
(12')
in
height.
For
lighting
requirements,
refer
to
Section
18.40.250.
SECTION 5. Subsection (k) of Section 18.12.040 (Site Development Standards) of Chapter
18.12 (R-1
Single-Family
Residential
District)
of
Title
18 (Zoning)
of
the
Palo
Alto
Municipal
Code
is
amended
to
read
as
follows
(additions
underlined
;
deletions
struck-through
):
(k) Lighting Recreational and security lighting shall be permitted only so long as the lighting is shielded so that
the
direct
light
does
not
extend
beyond
the
property
where
it
is
located.
Free-standing
recreational
and
security
lighting
installed
on
or
later
than
March
11,
1991
shall
be
restricted
to
twelve
feet
(12')
in
height.
Direct
light
from
outdoor
fixtures
shall
only
fall
on
the
walls,
eaves,
and
yard
areas
of
the
site
on
which
it
is
located.
Outdoor
fixtures
shall
have
lens
covers
or
reflectors
that
direct
the
light
away
from
the
neighboring
properties.
For
lighting
requirements,
refer
to
Section
18.40.250
.
SECTION 6. Subsection (n) of Section 18.28.270 (Additional OS District Regulations) of Chapter
18.28 (Special
Purpose
Districts)
of
Title
18 (Zoning)
of
the
Palo
Alto
Municipal
Code
is
amended
to
read
as
follows
(additions
underlined;
deletions
struck-through):
(n) Light and Glare
Exterior lighting should be low-intensity and shielded from view so it is not directly visible from off-site.
The
light
emitted
from
skylights
shall
be
minimal
during
the
night
hours.
Utilizing
treatments
such
as
translucent
glass,
shading
systems,
and
interior
light
placement
can
reduce
the
night
glare.
Skylights
shall
not
use
white
glass.
For
lighting
requirements,
refer
to
Section
18.40.250.
SECTION 7. If any section, subsection, clause or phrase of this Ordinance is for any reason held
to
be
invalid,
such
decision
shall
not
affect
the
validity
of
the
remaining
portion
or
sections
of
the
Ordinance.
The
Council
hereby
declares
that
it
should
have
adopted
the
Ordinance
and
each
section,
subsection,
sentence,
clause
or
phrase
thereof
irrespective
of
the
fact
that
any
one
or
more
sections,
subsections,
sentences,
clauses
or
phrases
be
declared
invalid.
SECTION 8. The Council finds that this project is exempt from the provisions of the California Environmental
Quality
Act
(“CEQA”),
pursuant
to
Section
15061
of
the
CEQA
Guidelines,
because
it
can
be
seen
with
certainty
that
there
is
no
possibility
that
the
ordinance
will
have
a
significant
effect
on
the
environment
and
Section
15308,
as
an
action
by
a
regulatory
agency
to
protect
the
environment.
SECTION 9. This ordinance shall be effective on the thirty-first day following its adoption. SECTION 10. This Ordinance shall not apply to any project application deemed complete prior to
the
effective
date
of
this
Ordinance.
From: Tiffany Griego
To: Cha, Kelly; Council, City; Clerk, City
Cc: Shweta Bhatnagar; Diana O"Dell; Jean G. Snider; Kelly Kline; Jamie S. Jarvis; Inglis, Jim Subject: Stanford Comments: 12/8/25 City Council Hearing on the Lighting Ordinance Update Date: Thursday, December 4, 2025 4:46:41 PM
Attachments: 2025-11-04__ Comment Ltr Dark Sky Ordinance - Stanford University.pdf CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.
Dear Mayor Lauing and Members of the City Council,
Please find enclosed Stanford University’s comments related to the Dark Sky Lighting Ordinance as it affects private lessees and tenants in Stanford Research Park.
We are resending our initial letter because it was not included in the packet distributed to you in advance of the 12/8/25 hearing.
Thank you in advance for your efforts to respond to these comments.
Respectfully submitted,
Tiffany Griego
Senior Managing Director, Stanford Research Park
Take advantage of our transportation programs:
www.SRPgo.com, a service of Stanford Research Park
From: Cha, Kelly <[email protected]>
Sent: Friday, October 31, 2025 10:54 AM
Cc: Cha, Kelly <[email protected]>
Subject: 11/10/25 City Council Hearing on the Lighting Ordinance Update
Hi everyone -
Thank you for your continued interest and participation in the Lighting Ordinance Update effort. The Lighting Ordinance Update item is scheduled for the upcoming City Council Hearing on November 10, 2025. Please review the staff report and associated attachment from the City Council Meeting Agenda page here
. The Lighting Ordinance Update is Item #8 on the agenda.
Please review the PUBLIC COMMENTS
section of the agenda to find out how to send your written comments in advance of the meeting, and how to participate and provide your comments orally in- person and virtually.
As always, if you have any questions or problem accessing the staff report and associated attachments for the Lighting Ordinance Update item, please do not hesitate to contact me.
Thanks again for your continued interest and participation in this effort,
Kelly Cha (she/her)
Senior Planner
Planning and Development Services
(650) 329-2155 | [email protected]
www.PaloAlto.gov
1 of 1
November 4, 2025
Palo Alto City Council
City of Palo Alto
250 Hamilton Avenue
Palo Alto, CA 94301
Re: City Council Consideration of Lighting Ordinance
VIA EMAIL [email protected]
Dear Mayor Lauing and Members of the City Council,
We would like to extend our sincere thanks to the City Council for the opportunity to provide feedback on the proposed changes to the Lighting Ordinance. As the landowner of Stanford Research Park, we are concerned that the proposed Lighting Ordinance pose s substantial design and implementation challenges for both the University and our tenants in the Research Park area.
We attended the October webinar outreach meeting that was organized by the Chamber and City staff to engage with business owners. We echo many of the concerns shared by fellow owners and tenants during the discussion. Based on our preliminary review, we believe that it may not be feasible to comply with the proposed standards while also maintaining the safety, security, and regulatory compliance that are essential to our operations and responsibilities as a property owner.
Safety Considerations: Outdoor lighting in the Research Park is intentionally designed to provide consistent and adequate coverage based on fixture type, bulb strength, and layout. Requiring changes such as adding motion sensors, shrouds, or altering fixtures and bulbs would lead to poor and unsafe lighting conditions. Motion-activated lighting does not provide a sense of safety or security, especially in a complex where tenants do not have fixed closing hours. Maintenance, janitorial, and security staff are often on -site after midnight, and researchers and engineers regularly work late as deadlines approach. This could also apply to future tenants. A low-lit campus, particularly with motion sensors, would feel unsafe and unwelcoming at night. This is also concerning as it relates to parking garages, where consistent lighting is essential for visibility and security . We urge the City to reconsider these proposed requirements and allow more flexibility for multi-tenant office sites.
Implementation Costs: The commercial office market is already under significant stress, and the proposed lighting standards would place an added burden on property owners. Upgrading lighting can be costly and may require extensive parking lot redesign, including relocating light poles and trenching to modify concrete, asphalt, trees, utilities, and drainage systems. We urge the Council to consider the financial and practical impacts on property owners and explore more flexible approaches to implementation.
Policy Standards and Regulatory Alignment : Retrofitting existing lighting fixtures for Dark Sky compliance requires a qualified lighting designer to ensure all specifications are properly met. This process includes conducting photometric studies to achieve correct lighting levels, ensuring JA8 and Title 24 compliance, meeting ADA requirements, and incorporating a 3000 Kelvin LED light source for improved visual acuity. To provide more detail: a light source with a color temperature of 2700 Kelvin, while ideal for indoor settings, appears too yellow for nighttime outdoor environments. This warmer tone can reduce visual acuity and is not suitable for an outdoor environment that is based on a bluer light. Conversely, color temperatures above 3000 Kelvin tend to appear too blue. A 3000 Kelvin light, which produces a neutral white tone, is considered optimal according to studies. Considering this, Stanford respectfully requests that the maximum allowable standard be adjusted to 3000 Kelvin. This adjustment would also ensure greater product availability and flexibility in meeting the ordinance.
We are also concerned about potential conflicts with California Title 24 and Cal/OSHA lighting requirements. These state and federal standards may supersede local regulations, rendering parts of the proposed ordinance unenforceable. We urge the City to car efully evaluate these overlaps to avoid legal and practical inconsistencies.
Finally, the current proposal would require all properties to come into full compliance within five years of the ordinance’s effective date. This timeline may place an undue burden on property owners, particularly given the costs and logistical complexity involved . We re quest that the City exempt existing buildings and apply the new standards only to new construction projects.
We want to encourage the City to keep Palo Alto attractive to business and appreciate the City Council’s thoughtful consideration of our comments. Please reach out to our team with any questions. We appreciate your consideration, and please let me know if you have further questions at [email protected]
Sincerely,
Tiffany Griego
Senior Managing Director, Commercial Real Estate
Stanford Real Estate, Stanford University
[email protected]
cc: Jonathan Lait, Director of Planning and Development Services Jennifer Armer, Assistant Director, Planning and Development Services Coleman Frick, Long-Range Planning Manager, Planning and Development Services Kelly Cha, Senior Planner, Planning and Development Services
From: Alexandra Mendoza
To: Council, City
Subject: City Council Meeting, December 8th: Agenda Item 15. Dark Skies Ordinance Date: Wednesday, December 3, 2025 5:37:27 PM
Attachments: Agenda Item. 15 Dark Sky Ordinance.pdf
CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.
i
Hello,
Attached is Green Foothills written comment for City Council's Agenda Item. 15 on December 8th.
Thank you!
Lexi Mendoza
photo Alexandra Mendoza (She/Her)
Environmental Associate
Green Foothills | (650) 968-7243 | greenfoothills.org
Double your donation by 12/31 thanks to a 2X matching grant. Donate today.
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1 December 3, 2025
Palo Alto City Council
250 Hamilton Ave
Palo Alto, CA 94301
[email protected]
Re: Agenda Item 15 – Support for the Dark Sky / Outdoor Lighting Ordinance Dear Mayor and Councilmembers:
Green Foothills urges you to adopt a strong Dark Sky Ordinance on December 8. Protecting natural darkness is essential for the health of Palo Alto’s nature preserves, wildlife corridors, and the Baylands.
Artificial light at night disrupts navigation, feeding, and reproductive cycles for wildlife and erodes the ecological integrity of the very habitats the City has worked hard to protect. Reducing unnecessary lighting is a simple, high-impact step that restores more natural nighttime conditions, limits skyglow, and strengthens the resilience of our remaining open spaces.
A strong ordinance will help ensure that wildlife, residents, and future generations can continue to experience the beauty of the night sky and the ecological richness of Palo Alto’s natural areas.
Thank you for your continued commitment to environmental stewardship.
Sincerely,
Alexandra Mendoza
Environmental Associate, Green Foothills
From: Tina Peak
To: Council, City
Subject: Please pass a Dark Sky Ordinance
Date: Wednesday, December 3, 2025 4:36:58 PM
CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.
i
Dear Mayor Lauing and Palo Alto Councilmembers,
I feel that the city should quickly adopt the Dark Sky Ordinance. It is imperative to focus on protecting the environment and the wildlife that lives in our urban area. People should attempt to have the least possible impact on other animals that we share space with.
Setting appropriate lights-out times, installing lower light level fixtures and preventing spill over lighting are all important components to the plan. And these are not difficult modifications to make.
I look forward to seeing these common sense limits on the light pollution that is present throughout the city.
Regards,
Tina Peak
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From: Lois Fowkes
To: Council, City
Subject: night sky
Date: Wednesday, December 3, 2025 3:05:46 PM
CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.
Dear City Council:
I am writing to support a strong ordinance in Palo Alto to keep the night sky dark, or rather, to make the night sky darker. The ambient light here is so much that birds are disoriented. It also interferes with hormone production, breeding, and migration. The lighting can even attract prey.
Please recognize the value of bird life here, and protect it by keeping public lighting low.
Thank you,
Lois Fowkes
From: Lauren Weston
To: Council, City
Subject: Re: Dec 8 Agenda Item 15 – Support for the Dark Sky / Outdoor Lighting Ordinance Date: Wednesday, December 3, 2025 1:31:12 PM
CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.
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Dear Mayor Lauing and Councilmembers:
Acterra strongly encourages you to approve a robust Dark Sky (Outdoor Lighting) Ordinance on December 8. Limiting excessive outdoor lighting offers a straightforward and impactful approach to reduce energy consumption, decrease greenhouse gas emissions, and support Palo Alto's climate and sustainability objectives.
Overabundance of nighttime illumination also negatively affects wildlife, interferes with human sleep patterns and well-being, and creates light pollution that degrades our community's quality of life. By directing light only to areas where it's necessary and at appropriate times, Palo Alto can enhance public health, cut emissions, and preserve the natural nighttime landscape.
A comprehensive ordinance will provide both immediate and enduring advantages for residents, local ecosystems, and our climate. We urge the Council to embrace this vital measure toward building a healthier, more sustainable community.
Sincerely,
Lauren Weston (she/her), EMBA
Executive Director
Acterra: Action for a Healthy Planet
(530) 219-2813
acterra.org | Subscribe
Acterra staff use self-identified pronouns to support workplace inclusion for everyone.
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the Ramaytush Ohlone and/or the Yokutz. Whose land are you on? In alignment with our values, we practice Slow Fridays (reducing internal and external meetings to focus on other areas of our work!).
From: April A.
To: Council, City
Subject: 12/8/2025 Agenda Item 15: We need a strong Outdoor Lighting Ordinance Date: Wednesday, December 3, 2025 11:06:11 AM
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i
City Council Members:
I am a resident of Palo Alto and have lived here over 30 years. My home is located directly across the street from the Fairmeadow and JLS schools. I'm very interested in seeing a strong outdoor lighting ordinance adopted to protect migrating birds, save energy, and minimize the negative impact on the residents of Palo Alto.
I am regularly impacted by nuisance lighting around my home and would like a city ordinance to address this. Two neighbors behind my home have lights that are left on 24 hours a day, and both shine into my windows. Worse than that, both schools across the street routinely have bright overhead lights left on in classrooms overnight, sometimes for days and days. Not only is this annoying and visible in my home, but my tax dollars are paying for wasted energy costs. These are not outdoor security lights, they are classroom lighting that should have timers installed to turn them off.
I encourage you to vote to adopt a strong ordinance to protect humans, birds, and our night sky, including the following recommended by Santa Clara Valley Bird Alliance and the Sierra Club:
Require all nonessential outdoor lighting to be turned off by 11:00 PM with reasonable exceptions, rather than midnight.
Require all new buildings, remodels, and fixture replacements to meet compliant lighting standards.
Remove the sunset deadline that would otherwise require citywide fixture replacement.
Apply the prohibition on blinking, flashing, rotating lights, as well as searchlights, aerial lasers, and spotlights, citywide, including Edgewood.
Require existing adjustable lighting to be compliant within one year of the effective date of the ordinance.
Thank you for your consideration of my issues and opinions.
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April Austin
East Meadow Drive
Palo Alto, CA
From: Drey
To: Council, City
Subject: 12/8/25 Agenda Item 15: Please reduce Light pollution Date: Tuesday, December 2, 2025 5:33:59 PM
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i
Dear Mayor Lauing and Council,
I grew up in Palo Alto, and appreciated being able to look up at the night sky from my backyard and actually see the stars. That’s become much harder over the years as bright outdoor lighting has increased in neighborhoods across the city. I’m writing to ask you to adopt a strong Dark Sky Ordinance on December 8 and to include the Sierra Club’s amendment requiring nonessential lighting to be turned off by 11:00 PM.
This is a small, reasonable change that will help restore some of the natural nighttime environment many of us remember. It will also reduce energy waste and help Palo Alto meet its climate goals. And for residents like me, it will make our neighborhoods feel calmer, healthier, and more connected to the natural world that surrounds us.
Please strengthen the ordinance with the 11 PM shut-off. It’s the right step for our community, our health, and the environment.
Thank you for your consideration.
Drey Kaiser
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From: Ala Romanowicz
To: Council, City
Subject: 12/8/25 Agenda Item 15: We need dark nights
Date: Tuesday, December 2, 2025 5:19:22 PM
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i
Dear Mayor Lauing and Councilmembers
I’m writing as a Palo Alto resident and a European immigrant who was drawn to this community partly because of its strong environmental values. Growing up in Europe, I was used to seeing cities manage lighting more thoughtfully, with earlier shut-off times and a clear awareness that darkness is part of a healthy environment. I believe Palo Alto can do the same.
I strongly support the Dark Sky Ordinance, and I hope you will adopt the Sierra Club’s amendment to require nonessential lighting to turn off by 11:00 PM. This small adjustment would reduce the harsh lighting that affects sleep in many neighborhoods, cut energy waste during the quietest hours of the night, and help protect the migrating birds and insects that still move through our city.
For me, part of feeling at home here is knowing that Palo Alto is committed to practices that respect both people and nature. This amendment is a practical, meaningful way to do that.
Thank you,
Tris
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From: Daniel Hansen
To: Council, City; Lauing, Ed; Cha, Kelly
Cc: Francois, Matthew; Lait, Jonathan; Armer, Jennifer; Shikada, Ed; Stump, Molly; Cha, Kelly Subject: Proposed Lighting Ordinance (18.40.250)
Date: Tuesday, December 2, 2025 12:16:18 PM
Attachments: Letter Regarding Lighting Ordinance - Edgewood Exemption and Prohibited Lighting.pdf CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.
Dear Honorable Mayor, Members of the City Council and Ms. Cha, Please see the attached letter submitted on behalf of the Edgewood Neighborhood Alliance regarding the Proposed Lighting Ordinance (18.40.250).
Best regards,
Daniel Hansen
Via Email
[[email protected]; [email protected]; [email protected]] December 2, 2025
Honorable Mayor and Members of City Council and Kelly Cha City of Palo Alto
250 Hamilton Avenue
Palo Alto, CA 94301
Re: Updating Section 18.40.250 (Lighting), Amending Chapters 18.10, 18.12, 18.28, and Section 18.40.230 of Title 18; Tentatively Scheduled for City Council Hearing on December 8, 2025
Dear Honorable Mayor and Members of the Palo Alto City Council and Ms. Cha:
In our prior letter dated November 6, 2025, we pointed out a typographical error in the exemption for Edgewood properties in the proposed Lighting ordinance. Staff has acknowledged the error and recommends its correction, as do we, as follows:
(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).
If this language is not removed, the exemption would apply only to 15 of the 52 properties on Edgewood, which is clearly not the intent.
The Santa Clara Valley Bird Alliance and the Sierra Club Loma Prieta Chapter, in their letter dated November 6, 2025, suggest that the Edgewood exemption be further modified to expressly say the properties are subject to the prohibitions in Section 18.40.250(g) (Prohibited Lighting). While well meaning, this suggestion is wrong as a matter of statutory construction and should be rejected. If this is accepted, it will infer that the other five exempt categories, including seasonal lighting, illuminated street numbers and emergency shelters, would not be subject to the prohibited lighting restriction, which is obviously not intended.
As drafted, Section 18.40.250(g) prohibits certain lighting as follows:
(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.
The Prohibited Lighting provision applies to all properties as a matter of normal statutory interpretation. Only airport lighting is exempt. The airport exemption specifically states, “Nothing in this section shall be interpreted to restrict, limit, or otherwise regulate” airport lighting. None of the other exemptions are prefaced with this savings language. Rules of statutory construction would therefore say that, except for airport lighting, all of the exempt categories in Section 18.40.250(d) remain subject to the Prohibited Lighting provision.
If, as requested by the environmental advocates, the exemption for Edgewood Drive properties—but not any of the other five exemption categories—were made expressly subject to the Prohibited Lighting provision, rules of construction would compel the opposite interpretation that the other five exempt categories are not subject to the prohibitions. This would lead to confusion and illogical outcomes.
It would mean, for example, that seasonal lighting displays could include searchlights, spotlights and aerial lasers (Section 18.40.250(d)(4)). Illuminated street numbers could have rotating or flashing lights (Section 18.40.250(d)(1)). Emergency Shelters would be free to employ blinking, flashing or rotating outdoor lighting and searchlights (Section 18.40.250(d)(6)).
The request to add specific reference to prohibited lighting in the Edgewood exemption should be declined because it is unnecessary and would result in confusion and the unintended consequence of the reading out the prohibited lighting limitations on the other exemptions.
Respectfully submitted,
EDGEWOOD NEIGHBORHOOD ALLIANCE
By, its representative,
Daniel Hansen
cc: Matthew D. Francois, Rutan & Tucker, LLP
Jonathan Lait, Director of Planning & Development Services Jennifer Armer, Assistant Director of Planning & Development Services Ed Shikada, City Manager
Molly Stump, City Attorney