Item 14 Public Comment — Palo Alto City Council, March 16, 2026

From: Tiffany Griego
To: Council, City; Clerk, City
Cc: Lait, Jonathan; Shweta Bhatnagar; Armer, Jennifer; Frick, Coleman; Cha, Kelly; Kelly Kline; Jamie S. Jarvis; Diana O"Dell; Jean G. Snider
Subject: 3/16 City Council hearing on the Bird-Friendly Design Ordinance Date: Friday, March 6, 2026 12:40:09 PM
Attachments: 2026-03-05__Bird Safe Buildings Comment Letter - Stanford University.pdf CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.

Dear Mayor Veenker and Members of the City Council,
Please find enclosed Stanford University’s comments related to the draft Bird-Friendly Ordinance related to impacts to Stanford Research Park ad Shopping Center.

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]>
Date: Friday, March 6, 2026 at 10:33 AM
Cc: "Cha, Kelly" <[email protected]>
Subject: 3/16 City Council hearing on the Bird-Friendly Design Ordinance Hello everyone -
I would like to share with you that the Bird-Friendly Design Ordinance will be heard before the City Council on March 16, 2026. Please check out the online agendato see the staff report and associated attachments. The ordinance is scheduled as Item #14 under Action Items. Please be informed that the time estimated on the agenda is an estimate, but could be changed as the council discussion progresses.

If you would like to send written comments or provide oral comments at the hearing, either in person or virtually, please read the PUBLIC COMMENTS section of the online agenda.

If you have any questions, please do not hesitate to contact me.

Thank you for your continued participation in this effort, Kelly Cha (she/her)
Senior Planner
Planning and Development Services
(650) 329-2155 | [email protected]
www.PaloAlto.gov

March 5, 2026

Palo Alto City Council
City of Palo Alto
250 Hamilton Avenue
Palo Alto, CA 94301
VIA EMAIL [email protected]

Re: City Council Consideration of Bird-Friendly Design Ordinance

Dear Mayor Veenker and Members of the City Council,

On behalf of Stanford University and Stanford Research Park, I would like to extend our sincere gratitude to City staff for their continued hard work on the proposed Bird -Friendly Design Ordinance. In this letter, we reiterate the concerns shared with the C ity over the past months, including those raised during the January webinar for business owners. As the landowner of the Stanford Research Park and Shopping Center , we are concerned that the proposed ordinance poses significant design and implementation challenges for remodels and new construction, particularly new residential construction.

We strongly recommend that City Council revise the ordinance to (1) limit the new restrictions to office/R&D properties located within the Bird Sensitive Area boundaries that were originally recommended by the PTC , and (2) exempt all residential buildings regardless of location within the City. The reasons are many:

1. The draft ordinance as written, which includes triggers for window replacement, would force landlords in Stanford Research Park to retrofit all windows with bird -friendly glazing even if tenant -required remodeling or repositioning scope would otherwise exclude existing windows. Forcing landlords to replace windows when they otherwise would not opt to is so costly that it would put a chill on proactive reinvestment in the existing building stock in SRP. Over time, without proactive reinvestment, SRP would see a gradual degradation, affecting business and property tax revenue generation.

2. Staff has acknowledged the added cost burden resulting from this draft ordinance, which would c urtail the construction of new high -density residential development, when this product type is already challenged by the high-cost burden.

3. The City should not make policy without data and a valid justification for including sites that are outside of a riparian corridor or migratory path.

Targeted Regulations: The current requirements do not consider the diverse conditions throughout the City, and there is limited reliable data on bird-building conflicts in areas beyond the designated Bird Sensitive Area. As a viable alternative, we suggest adopting San Francisco’s Bird-Safe Building Standards, which provide a more nuanced approach by limiting required treatments to buildings in expansive open spaces or near water, as well as specific architectural features that may pose a bird hazard. This approach represents a more balanced strategy, avoiding a one -size-fits-all approach throughout the City. We support targeted regulations that focus on the specific Bird Sensitive Areas and exempt new residential construction.

Insufficient Data: While we understand that the ordinance aims to mitigate bird collisions, there is no comprehensive data that speaks to the scope of this issue. The proposed ordinance would require fairly sweeping changes throughout the City based on insufficient data. To date, we are unaware of any documented bird collisions within Stanford Research Park and Shopping Center. Since most of our buildings are two stories tall and not situated on a flyway or riparian corridor, we believe it is crucial to conduct a data -driven assessment of local collision frequencies, risk factors, and anticipated outcomes to justify the extensive breadth and costs of these requirements. As was called for in the Comprehensive Plan Policy L-6.3, we respectfully request that the City undertake a study before developing guidelines for bird-friendly design (rather than this ordinance).

Altered User Experience, Limited Supply Chain, and Higher Costs : The use of bird -friendly glass significantly impacts building occupants' experiences due to the visible lines and dots on windows, which detract from aesthetic appeal , especially without clear evidence of local benefits. The ordinance suggests allowing only 10% untreated glazing on any non- residential elevation citywide, requiring commercial buildings to have permanent glass treatments with patterns no more than two inches apart to minimize co llision risks for birds. This broad requirement fails to consider essential factors like overall benefits, occupant experience, and construction costs , especially new residential construction . (See Ex. A for example photos taken at 3215 Porter Drive.) It inadvertently increases expenses while negatively impacting user experiences. Additionally, the limited availability of bird -friendly treatment materials raises concerns that a sudden demand increase could strain resources and delay projects, highlighting the need for a reliable supply chain before implementing any mandates. We urge the City to adopt an approach that allows a broader range of practical alternatives outside of permanent glazing treatments.

In conclusion, we encourage the C ity to maintain Palo Alto's appeal to businesses while exploring bird -friendly design options and non -binding guidelines that align with best practices from neighboring jurisdictions. Stanford Research Park already balances environmental initiatives and economic viability. We have voluntarily installed bird-glass on all bus shelters and in some new developments in SRP near potential migratory paths.

We appreciate your consideration, and please let me know if you have further questions at [email protected].

Sincerely,

Tiffany Griego,
Senior Managing Director
Stanford Real Estate, Stanford University

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

Exhibit A:

Bird-glass film, installed voluntarily at 3215 Porter Drive, shows the significant compromise to user experience.

From: Laura Bowser
To: Council, City; Lait, Jonathan; Armer, Jennifer; Cha, Kelly Subject: Bird-Friendly Design Ordinance (March 16, 2026 - Agenda Item #14) Date: Monday, March 16, 2026 10:05:32 AM
Attachments: SHP Letter re Bird Ordinance - Mar 16 2026.pdf CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.

Councilmembers of the City Council,

Please see attached for our comments regarding the proposed Bird Safe Ordinance under consideration at tonight’s meeting.

Best,
Laura

Laura Bowser
Sand Hill Property Company
2600 El Camino Real, Suite 410
Palo Alto, CA 94306
Tel. +1 650 344 1500
2600 El Camino Real, Suite 410 | Palo Alto, California 94306March 16, 2026 Re: Ordinance re: Bird-Friendly Design (Council Hearing March 16, 2026 – Item #14) Dear Mayor and Members of the City Council: On behalf of Sand Hill Property Company (SHP), we are writing regarding the proposed Bird-Friendly Design Ordinance (Ordinance). SHP values its longstanding working relationship with the City and is committed to delivering and maintaining high quality projects that support the City’s goals, including new housing and reinvestment in existing development. We appreciate the work that Planning staff has undertaken to address a challenging issue. However, SHP respectfully urges the City Council not to adopt the Ordinance in its current form and instead allow staff additional time to conduct further analysis before adopting a policy with significant impacts. While SHP supports the City’s objective of addressing legitimate bird-safety concerns, the current Ordinance imposes a sweeping solution before the City has adequately diagnosed the problem it is trying to solve. The Ordinance is not sufficiently tailored to local conditions and will create substantial unintended consequences for existing property owners, future investment, and new development without evidence that such a broad approach is warranted. These concerns echo the substantial stakeholder feedback already provided to the Planning Commission and City Council, which has consistently called for additional study and a more carefully tailored ordinance before adoption. These concerns are particularly important given the City’s substantial RHNA obligations and its ongoing need to facilitate multifamily housing production. As drafted, the Ordinance would materially affect the design, cost, and feasibility of multifamily residential and other projects at a time when the City should be focused on removing unnecessary barriers to housing and reinvestment. For these reasons, SHP respectfully requests that the City Council defer adoption of the proposed Ordinance and instead direct staff to return with a more fully studied proposal that better considers local conditions, best practices, and engagement with stakeholders. The Ordinance needs to address the actual risks and adopt an approach that can effectively address real bird-safety concerns without inadvertently creating significant new problems.

Mayor and Members of the City Council, City of Palo Alto [email protected]; [email protected]; [email protected]; [email protected] [email protected]; [email protected]; [email protected]; [email protected] * * * Thank you for your time and attention to this issue. We look forward to continuing to work with Planning staff and decisionmakers on an approach that addresses bird-safety concerns in a practical and effective manner. Sincerely, Laura Bowser Director, Development Sand Hill Property Company Copies: Jonathan Lait, Director, Planning & Development Services [email protected] Jennifer Armer, Asst. Director, Planning & Development Services [email protected] Kelly Cha, Senior Planner, Planning & Development Services [email protected]

From: Tom Fountain
To: Council, City
Cc: Cha, Kelly
Subject: "Bird-Friendly" Design Ordinance
Date: Sunday, March 15, 2026 9:42:53 PM
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Dear Mayor Veenker and Members of the City Council,
With respect to the proposed "Bird-Friendly" Design ordinance, I am writing in support of an exemption for residential buildings.

Specifically:

Lack of Local Bird-Collision Studies. There are no data or studies of bird collisions in Palo Alto, commercial or residential, nor any in neighboring jurisdictions. The advocates for this new ordinance generally base their conclusions on studies conducted elsewhere covering different species of birds with different migratory patterns. Analyses of the relevant bird species, their propensity to collide, and impact of conservation efforts are needed before imposing costs on property owners.

The Burden of Compliance on Residential Development is Substantial. Bird-safe glass windows for residential use are not readily available and are prohibitively expensive. The alternatives of permanent metal screens and shades are impractical, expensive, aesthetically unappealing, obscure visibility, and are unsafe for fire escape. Similarly, the alternative of plastic dots or films are impractical and pollute the environment with microplastics and PFASs. Homes need unobstructed windows for safety to keep an eye on our children and see who is on the property. These burdens combine to unfairly reduce market value and slow housing development.

Adopt Non-Mandatory Bird-Friendly Design Guidelines. Direct staff to prepare and adopt guidelines consistent with the Comprehensive Plan’s authorization. Voluntary uptake under design review, combined with staff encouragement and public outreach, can generate meaningful real-world experience with residential bird-safe design in this community.

Follow the Lead of San Francisco, Richmond, Alameda and Berkeley. If residences are to be regulated, the city should follow the lead of San Francisco, Richmond, Alameda and Berkeley, as recommended by the Planning & Transportation Commission. These cities exclude residential homes unless over 45 or 35 feet and with large facade of glass (e.g., 50% or more glass), in which case, the bird-safe requirements apply to large glass panels (e.g., 24 square feet or more). These cities reached a fair balance of benefit against burden and give home designers a choice whether to have large glass panels.

Thank you,
Tom Fountain
From: Shani Kleinhaus
To: Council, City
Cc: Clerk, City; Cha, Kelly; Dash Leeds
Subject: Bird-Friendly Design Ordinance – Context from other Bay Area ordinances Date: Sunday, March 15, 2026 2:35:45 PM
Attachments: Palo Alto Updated Applicability Table (3).pdf Palo Alto Bird Safety Standards (raw language) comparison (3).pdf CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.

Bird-Friendly Design Ordinance – Context from Other Cities Dear Mayor Veenker and Councilmembers,
We prepared the attached comparison tables
(Sheet 1 Applicability,Sheet 2 Standards) to
show how Palo Alto’s proposed Bird-Friendly Design Ordinance fits within policies already adopted by other Bay Area jurisdictions.

Cities in the region have adopted a broad spectrum of applicability and standards for bird-friendly design.

Palo Alto’s proposed ordinance falls in the middle of this range. It is the result of many years of vetting by multiple city boards, commissions and the community, and over time, its applicability and scope have narrowed. We believe that it now represents a reasonable, Palo Alto appropriate result.

The proposed standards fall well within the mainstream of current practice. Other cities use similar bird-friendly glazing requirements, limits on untreated glass, and design standards for hazardous features such as transparent corners, skyways, glass railings, and other large reflective or see-through surfaces.

The comparison also shows that bird-friendly standards are commonly applied to both residential and non-residential development and typically focus on lower building elevations where most bird collisions occur.

Importantly, several jurisdictions that have adopted bird-friendly design requirements have also received state recognition as Prohousing Designated Jurisdictions.This demonstrates that adopting bird-friendly design standards is compatible with housing production and does not impede a city’s ability to obtain or maintain Prohousing designation.

Bird-friendly design ordinances are now a common planning tool that can protect wildlife while remaining compatible with Palo Alto's housing goals.

Respectfully,
Shani Kleinhaus
Shani Kleinhaus, Ph.D.

Environmental Advocate
Santa Clara Valley Bird Alliance
22221 McClellan Rd.

Cupertino, CA 95014
650-868-2114
[email protected]

From: Diane McCoy
To: Council, City
Subject: Please protect birds
Date: Sunday, March 15, 2026 9:29:10 AM
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Dear Mayor Veenker and Palo Alto Councilmembers,
My name is Diane McCoy and have been a Palo Alto resident since 1978.

Before that, since 1959 I have spent all my childhood summers in Palo Alto, 'summer camping' at my grandma's house. My grandma and grandpa's love of Palo Alto, especially it's neighborhood parks and bay lands (sooooo many walks to the Duck Pond!) greatly influenced my appreciation for being able to be a resident here.

Since 1959 (and earlier even) Palo Alto has continued to grow and grow and grow, in many ways, as it happens in life. But I've always been proud and appreciative of the way our city usually advocates and supports environmental values; we have almost all electric everything (heaters, a/c/ stove, water heater, solar panels, etc.) thanks partly to city supportive measures.

Please continue that legacy.

Thus, I am writing to ask you to adopt the Bird-Friendly Design Ordinance as drafted.

Please reject staff-recommended changes that could weaken the ordinance, such as expanding the 35-foot exemption to all development types. Most bird collisions occur at tree-canopy height, and expanding this exemption would remove protections where they are most needed.

There are many bird-safe window treatments and design options available, and these should be used rather than exempting commercial buildings.

Thank you for your service to our community.

Diane McCoy
Greer Road
From: Prisha Goel
To: Council, City
Subject: Subject: Support for the Bird-Friendly Design Ordinance Date: Sunday, March 15, 2026 12:49:38 AM
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i
Dear Mayor Veenker and Palo Alto Councilmembers,
My name is Prisha Goel, and I am a junior at PAMC passionate about the preservation of our local wildlife. I noticed our city is harming the lives of many birds. Living in Palo Alto, I have had the opportunity to observe the vibrant birdlife that enriches our community.

However, I have also witnessed the tragic consequences of bird strikes, which have made me acutely aware of the need for protective measures.

I am writing to urge you to adopt the bird-friendly design ordinance as it is currently drafted. It is crucial to reject any staff-recommended changes that could weaken this ordinance, particularly the proposal to expand the 35-foot exemption to all development types.

Most bird collisions occur at tree-canopy height, and expanding this exemption would significantly diminish the protections where they are most needed.

There are numerous bird-safe window treatments and design options available that can be integrated into new developments. I believe we should prioritize these solutions instead of exempting commercial buildings from necessary safeguards.

Thank you for your commitment to our community and for considering the well-being of our local bird populations.

Sincerely,
Prisha Goel
6507889694
Palo Alto Middle College
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From: Emily Renzel
To: Council, City
Subject: Please support bird friendly windows
Date: Saturday, March 14, 2026 5:28:23 PM
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i
Dear Mayor Veenker & Members of the City Council.

Please adopt the Bird-Friendly Design Ordinance as drafted. It is particularly important in our Baylands which are critical to bird migrations.

There are many bird-safe window treatments and design options available, and these should be used rather than exempting commercial buildings.

Thank you for protecting Palo Alto’s birds.

Sincerely,
Emily M. Renzel
Councilmember 1979-1992
Planning Commissioner 1973-79
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From: Avroh Shah
To: Council, City
Subject: In Support of a Strong Bird-Friendly Building Ordinance Date: Saturday, March 14, 2026 5:18:03 PM
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i
Dear Mayor Veenker and Palo Alto Councilmembers,
I hope you are all doing well. My name is Avroh, and I'm a junior at Paly. I think birds are pretty amazing, and I don't think it's fair to birds when they are harmed after ramming into barriers that are invisible to them. I have witnessed four bird strikes (two of which were fatal) in Palo Alto during my lifetime.

I am writing to ask you to adopt the Bird-Friendly Design Ordinance as drafted.

There are many bird-safe window treatments and design options available, and these should be used rather than exempting commercial buildings.

Thank you for your service to our community.

Sincerely,
Avroh Shah
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From: Kristin Sato
To: Council, City; Cha, Kelly
Subject: "Bird-Friendly" Design Ordinance
Date: Saturday, March 14, 2026 4:32:31 PM
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i
Palo Alto City Council, [email protected]
Kelly Cha, [email protected]
Re: "Bird-Friendly" Design Ordinance
Dear Mayor Veenker and Members of the City Council,
With respect to the proposed "Bird-Friendly" Design ordinance, I am writing in support of an exemption for residential buildings. Specifically:

Lack of Local Bird-Collision Studies. There are no data or studies of birds in Palo Alto colliding with buildings, whether commercial or residential. Analyses of the relevant bird species, their propensity to collide under the circumstances and their conservation risk are required to assess the risk to birds from houses.

The Burden of Compliance on Residential Development is Substantial. Bird- safe glass windows for residential use are not readily available and are prohibitively expensive. The alternatives of permanent metal screens and shades are impractical, expensive, aesthetically unappealing, obscure visibility, and are unsafe for fire escape. Similarly, the alternative of plastic dots or films are impractical and pollute the environment with microplastics and PFASs. Homes need unobstructed windows for safety to keep an eye on our children and see who is on the property. These burdens combine to unfairly reduce market value and slow housing development.

Adopt Non-Mandatory Bird-Friendly Design Guidelines. Direct staff to prepare and adopt guidelines consistent with the Comprehensive Plan’s authorization.

Voluntary uptake under design review, combined with staff encouragement and public outreach, can generate meaningful real-world experience with residential bird-safe design in this community.

Mark Safe Report
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Transportation Commission. These cities exclude residential homes unless over 45 or 35 feet and with large facade of glass (e.g., 50% or more glass), in which case, the bird-safe requirements apply to large glass panels (e.g., 24 square feet or more). These cities reached a fair balance of benefit against burden and give home designers a choice whether to have large glass panels.

Phase in the Ordinance. If residences are to be regulated, the ordinance should be phased in over 5-10 years to give time for residential window manufacturing to catch up and bird-collision studies to be completed.

Thank you for your consideration,
Kristin Sato

From: Bob Lenox
To: Council, City
Cc: [email protected]; Swanson, Andrew; Luetgens, Michael; Christopher Burtrum Subject: Bird Friendly Ordinance item 14, March 16, 2026 Date: Friday, March 13, 2026 9:05:14 PM
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Honorable Councilmembers,
This proposed ordinance must exempt the FAA Air Traffic Control Tower. Any obstruction to, or distortion of, visibility could present a safety-of-flight concern. ATC Controllers require a clear view of the surrounding surface and airspace in order to safely work aircraft. Please consider this before enacting this legislation.

Sincerely,
Bob Lenox, President
Palo Alto Airport Association
From: Claude Ezran
To: Council, City
Subject: Birdbrained idea: bird-friendly buildings in Palo Alto! Date: Friday, March 13, 2026 6:12:04 PM
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!
Dear City Council Members,

I hope you will decisively quash this birdbrained idea of mandating that we now have bird- friendly buildings in Palo Alto.

A little bird told me that the City of Palo Alto is not always paying close enough attention to the unintended consequences of its well-intended decisions.

Over time the City has been piling-up regulations on top of regulations on top of regulations. Each one of these regulations is, of course, well-intended. But if you step back and, for once, take a bird’s eye view to consider the end result of all of this, you will see a staggering pile of rules and regulations that substantially contributes to making housing construction very expensive in Palo Alto. Each one of these regulations adds complexity, costs, and delays to construction. And delays translate into additional costs: for instance, if you borrow $3M at 6% to build a house in Palo Alto, each single day that you lose waiting for a permit, a required report, an inspection, or the procurement of hard to find materials mandated by the City, will cost you about $500.

Does the City ever look back at this gigantic regulatory mountain and consider retiring some of these feel really good to pass but birdbrained and costly regulations that are not that beneficial anymore? I doubt it does.

It does not require an eagle eye to see that that the City is winging it. Where is the study showing the number of birds that actually die from building collisions each year in Palo Alto? How does this compare to the number of bird deaths due to natural causes such as birds being killed by predatory birds in Palo Alto? Are we making housing ever more expensive in Palo Alto in order to save the lives of something like five birds per year? What is the tradeoff?

This proposed ordinance and the recently passed dark sky ordinance are example of extreme environmentalism gone haywire. How many astronomical observatories do we have in Palo Alto? None, but we do have astronomical housing construction costs!

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Best regards,

Claude Ezran

From: Dashiell Leeds
To: Council, City
Cc: Clerk, City; James Eggers; Gita Dev; Sue Chow; [email protected]; [email protected]; Cha, Kelly; [email protected]
Subject: Support for March 16 Bird-Friendly Design Ordinance – Please Do Not Weaken Standards Date: Friday, March 13, 2026 3:55:36 PM
Attachments: SCLP, SCVBA, ABC letter to Palo Alto re Bird Friendly Design.pdf CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.

Dear Mayor Veenker and Palo Alto Councilmembers,
The Santa Clara Valley Bird Alliance, the Sierra Club Loma Prieta Chapter and the American Bird Conservancy support adoption of the Draft Bird-Friendly Design Ordinance adding Section 18.40.280 to the Palo Alto Municipal Code as proposed in Attachment A.

Please read the attached letter for our full comments.

Sincerely,
Matthew Dodder
Executive Director
Santa Clara Valley Bird Alliance
Dashiell Leeds
Conservation Coordinator
Sierra Club Loma Prieta Chapter
Kaitlyn Parkins
Glass Collisions Program Coordinator
American Bird Conservancy

March 13, 2026
Subject: Support Bird-Friendly Design Ordinance – Please Do Not Weaken Standards Dear Mayor Veenker and Palo Alto Councilmembers,
The Santa Clara Valley Bird Alliance, the Sierra Club Loma Prieta Chapter and the American Bird Conservancy

support

adoption

the

Draft

Bird-Friendly

Design

Ordinance

adding

Section

18.40.280

the

Palo

Alto

Municipal

Code

proposed

Attachment

A
.

Palo Alto residents consistently express strong support for protecting nature, biodiversity, and wildlife habitat,

reflected

City

policies

such

the

Comprehensive

Plan

and

the

Sustainability

and

Climate

Action

Plan.

Scientific research shows that
● Bird populations in North America are declining, and the decline is accelerating, ● Collisions with glass and other human-made structures are a major driver of this decline, ● Collisions occur wherever birds are active, and ● In urban and suburban landscapes, most collisions occur at tree-canopy height, from ground level to

roughly

60 feet.

Protecting birds is particularly important in Palo Alto, where birds are abundant not only in the Baylands and

foothills,

but

also

along

riparian

corridors

and

throughout

the

City’s

urban

forest,

supporting

large

numbers

migratory

and

resident

birds.

The Draft Ordinance defines Bird Sensitive Areas in the Baylands and the foothills (east of Highway 101 and

west

Foothill

Expressway).

Outside

these

Bird

Sensitive

Areas,

the

ordinance

does

not

apply

any

existing,

modified

new

portion

residential

structures

under

35 feet.

Routine window replacement does not automatically trigger bird-friendly treatment requirements unless the

glazing

would

otherwise

trigger

building

permit

and

falls

into

the

hazard

categories

defined

the

ordinance.

Therefore,

the

ordinance

does

not

apply

most

replacements

fenestration.

would

have

preferred

stronger

requirements

for

new

residential

development

and

major

remodels

order

avoid

creating

new

hazardous

architectural

elements,

but

recognize

that

this

ordinance

has

undergone

extensive

review

Boards

and

Commissions

and

reflects

substantial

community

input

across

multiple

commission and council terms. The result is a reasonable compromise, and we support adoption of the draft

ordinance

proposed.

Staff recommends that the City Council consider extending the 35-foot height exemption universally to all

development

types.

not

clear

whether

this

extension

would

remove

the

Bird

Sensitive

Area

qualifier.

We are strongly opposed to extending the 35-foot height exemption universally to all development

types

this

would

significantly

weaken

the

ordinance

and

create

very

low

benchmark

for

other

jurisdictions

follow.

pointed

out

above,

most

collisions

occur

tree-canopy

height,

from

ground

level

roughly

60 feet.

Alternatively, Staff recommends expanding the allowance of films and decals for non-residential projects, an

option

supported

local

businesses

order

provide

affordable

compliance

option

when

specialized

glazing

cost

prohibitive.

If Council wishes to extend the allowance of films or decals to non-residential projects, we ask council

direct

the

ordinance

limit

these

installations

products

that

are

approved

the

American

Bird

Conservancy,

and

require

the

installation

the

exterior-facing

surface

of
the glass, where they are most effective (https://abcbirds.org/products/).

Thank you for your leadership in protecting birds, biodiversity, and the natural character that residents value

Palo

Alto.

Sincerely,
Matthew Dodder Executive Director Santa Clara Valley Bird Alliance Dashiell Leeds Conservation Coordinator Sierra Club Loma Prieta Chapter Kaitlyn Parkins Glass

Collisions

Program

Coordinator

American

Bird

Conservancy

From: Victoria S. Ramirez
To: Council, City
Cc: Cha, Kelly; Molly Swenson (SHC)
Subject: SHC Letter of Concern Item 14 - Bird-Friendly Design (3/16/26) Date: Friday, March 13, 2026 1:09:21 PM
Attachments: image001.png
Bird Safe Design Ordinance SHC Comment Letter - 3-11-26.pdf CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.

Dear Honorable Mayor and members of the City Council,

Attached you will find a letter from Stanford Health Care providing feedback and expressing our concerns with Item 14 on the Monday, March 16 Council Meeting Agenda – Bird-Friendly Design.

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

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

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

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

March 13, 2026

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

Re: City Council Consideration of Proposed Bird-Friendly Design Ordinance

VIA EMAIL [email protected]; [email protected]

Dear Mayor Veenker and Members of the City Council,
Stanford Medicine appreciates the opportunity to provide feedback on the current iteration of the proposed Bird-Friendly Design Ordinance. As it relates to our medical campus, we have several concerns with the proposal, particularly related to applicability, implementation costs, and user experience.

We were invited to attend the virtual outreach meetings with Planning staff in October 2025 and January 2026, and share the concerns voiced in the outreach meetings regarding the lack of formal studies substantiating the need for this level of intervention and the negative impacts the bird-safe treatments would have on building users’ experience. Based on the review of the most current information, the proposed ordinance could negatively impact the design and costs of our future facilities.

We assert that the ordinance should be targeted to areas and situations in which bird collisions are most likely to occur rather than being applied as a blanket rule across the entire city. Ordinances in other jurisdictions, such as San Francisco and Oakland, are context-specific, requiring such measures for buildings adjacent to open spaces that are of a certain size (at least 1-2 acres) and consist of wetlands, open water, or heavy vegetation. For Palo Alto, applicability could be further informed for the local context through a formal study of bird collisions in the City; we view this as a critical step in establishing place- based policy.

Implementation of the ordinance as currently proposed would place a financial encumbrance on future development. It has been noted by staff that implementation expenses for landowners and developers have not been analyzed. This ordinance would demand the use of treated glass and/or significant façade elements to break up large areas of glazing. Project budgets would need to be realigned to account for these bird safe treatments. Based on recent cost estimates, using the existing glazing of Stanford Hospital at 500 Pasteur Drive as a benchmark, the use of bird-safe glass etched with dots would increase project glazing costs by approximately 18-20 percent. Implementation of the proposed requirements would take away funds from other elements that may have a more proven benefit, considering the necessity for bird-safe treatments in the City has not been firmly substantiated through a formal study.

Finally, the ordinance would dramatically impact the interior building experience for our staff, patients, and visitors. Bird-friendly treatments significantly alter the experience of building users with highly visible lines and dots on glazing and architectural elements that obstruct views. As demonstrated with Stanford Hospital located at 500 Pasteur Drive, clear unobstructed views of the surroundings from our patient spaces and other areas are a deliberate nod to biophilic design, shown in studies to improve overall patient outcomes and reduce stress on healthcare workers. With these noted benefits, the intent would be to carry this design language in the future development of our medical campus.

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

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

Sincerely,

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

From: Mr. Shore
To: Council, City; Cha, Kelly
Cc: Armer, Jennifer; Lait, Jonathan; Shikada, Ed; Arellano, Caio Subject: Bird-Friendly Design Standards Ordinance - March 16, 2026 - Agenda Item 14 Date: Friday, March 13, 2026 10:07:06 AM
Attachments: Palo Alto Airport Exemption - Bird-Friendly Design - 13 Mar 2026.pdf CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.
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Dear Mayor Veenker, Members of City Council and Ms. Cha, Please see the attached letter regarding the Proposed Bird-Friendly Design Standards Ordinance (18.40.280).

Best regards,
Jeffrey Shore
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March 13, 2026
VIA E-MAIL [[email protected] and [email protected]] Mayor Veenker and Members of the City Council
City of Palo Alto
250 Hamilton Avenue
Palo Alto, California 94301
Kelly Cha
Senior Planner
City of Palo Alto
250 Hamilton Avenue
Palo Alto, CA 94301
Re: March 16, 2026 Agenda Item 14 — Bird-Friendly Design Ordinance (PAMC § 18.40.280) Dear Mayor Veenker and Members of the City Council:

Please consider exempting the Palo Alto Airport (PAO), including the FAA-operated Air Traffic Control Tower, from the Bird-Friendly Design ordinance. To avoid unintended comparisons, it is suggested that the language of a PAO Bird-Friendly Design exemption should parallel the exemption for “Lighting for Airport Operations” in PAMC § 18.40.250(d)(1)(C). See Ordinance No. 5692.

Add new section § 18.40.280(g)(6) to read as follows:
"(g) Exemptions. The following types of projects shall be exempt from Section

18.40.280(d):
. . .
. . .
(6) Glazing for Airport Operations. Nothing in this section shall be interpreted to restrict, limit, or otherwise regulate glazing 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.

Respectfully submitted,

Jeffrey Shore

cc: Jonathan Lait, Director of Planning & Development Services Jennifer Armer, Assistant Director of Planning & Development Services Kelly Cha, Senior Planner
Ed Shikada, City Manager
Caio Arellano, Interim City Attorney

From: Mr. Shore
To: Council, City; Cha, Kelly
Cc: Armer, Jennifer; Lait, Jonathan; Shikada, Ed; Arellano, Caio; [email protected]; [email protected] Subject: Bird-Friendly Design Standards Ordinance - March 16, 2026 - Agenda Item 14 Date: Wednesday, March 11, 2026 11:14:11 AM
Attachments: Edgewood Neighborhood Alliance Supplemental Letter - Bird-Friendly Design Ordinance - 11 Mar 2026.pdf Edgewood Neighborhood Alliance Letter Regarding Bird-Friendly Design Ordinance - 02 Dec 2025.pdf CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.
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Dear Mayor Veenker, Members of the City Council and Ms. Cha, Please see the attached letter submitted on behalf of the Edgewood Neighborhood Alliance regarding the Proposed Bird-Friendly Design Standards Ordinance (18.40.280). This letter supplements our prior letter to the Planning & Transportation Commission, dated December 2, 2025, a copy of which is also attached to this email.

Best regards,
Jeffrey Shore
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March 11, 2026
VIA E-MAIL [[email protected] and [email protected]] Mayor Veenker and Members of the City Council
City of Palo Alto
250 Hamilton Avenue
Palo Alto, California 94301
Kelly Cha
Senior Planner
City of Palo Alto
250 Hamilton Avenue Palo Alto, CA 94301

Re: March 16, 2026 Agenda Item 14 — Bird-Friendly Design Ordinance (PAMC § 18.40.280) Dear Mayor Veenker and Members of the City Council:

We, the Edgewood Neighborhood Alliance, are writing in reluctant and qualified support of the proposed Bird-Friendly Design Ordinance (PAMC § 18.40.280) as recommended by the Planning and Transportation Commission (“PTC”).

In so doing, we are compelled to note that, even with the PTC’s acknowledgement of the lack of quantifiable data, two PTC members, including one member (James) who spent his entire career focused on conservation at National Geographic, voted against the PTC’s motion and recommended against adopting any ordinance because neither the local problem nor its solutions are sufficiently understood.

The truth is there are no local data that support this ordinance. In particular, there are no data of bird collisions with windows, residential or commercial, in Palo Alto. In the absence of data, Palo Alto should follow Sunnyvale and adopt guidelines for development. This is a solution in search of a problem.1
I. The Comprehensive Plan Only Authorizes Guidelines
At most, the Comprehensive Plan authorizes guidelines, not mandatory zoning restrictions. The Plan addresses bird-friendly building design at Policy L-6.3 and Program L6.3.1 — the only provisions staff have cited as Comprehensive Plan authority across every staff report, board and commission hearing over the past two years:
• Policy L-6.3: “Encourage bird-friendly design.”
• Program L6.3.1: “Develop guidelines for bird-friendly building design that minimizes hazards for birds and reduces the potential for collisions.”
“Guidelines” are defined by the Comprehensive Plan as “[p]rovisions guiding the design of buildings that are not mandatory but may be used by Staff, the City’s advisory boards and commissions and the City Council in evaluating projects.” (“Design Guidelines,” p. 289, emphasis added.)

1 This letter supplements our prior letter to the PTC, dated December 2, 2025, a copy of which is attached. Considering the PTC’s split-vote recommendation and its fundamental reservations with the ordinance, our prior letter remains highly pertinent. Prior public comments on the Bird-Friendly Ordinance do not appear to have been compiled and included in Council’s Packet for March 16, 2026.

Honorable Mayor and Members of the City Council
March 11, 2026

Page 2 ends

Under Government Code section 65860, a zoning ordinance that is inconsistent with the General Plan is void. (Lesher Communications, Inc. v. City of Walnut Creek (1990) 52 Cal.3d 531, 540, 545- 546.) Where the Plan uses permissive language and authorizes a non-mandatory instrument, a mandatory ordinance directly conflicts with that authorization. No other Comprehensive Plan provision cures this defect. The draft ordinance’s own Section 1(A) recites that the Plan “included a policy encouraging bird-friendly design and a program to develop guidelines,” then proceeds to enact mandatory requirements with no consistency analysis. Under Lesher, that omission is fatal.

II. The Proposed Ordinance Would Burden Housing Development We share the commitment to bird conservation, and we do not question the importance of investigating bird-window collisions. But the ecological case for imposing mandatory residential mitigations rests on extrapolations from generalized bird-window collision data, mostly from the East coast, which have not been validated in the local context.2 Bird abundance decline is driven by myriad contributing causes: habitat loss, predation, climate change, high-intensity agricultural activities, and outdoor cats, among others.3 The relative contribution of residential window collisions to local bird population trends, and the marginal benefit of specific residential glazing interventions, have not been the subject of localized study in Palo Alto or the broader Peninsula. Before imposing costly mandatory constraints on residential housing development based on these extrapolations, the Council should have a clearer picture of what those constraints would accomplish.4 At scale, the compliance costs and project delays associated with the proposed mandatory measures could materially frustrate housing production5 — a significant harm in a jurisdiction under intense state housing pressure — while their avian ecological benefits in the residential context could prove illusory. Those costs and delays stem from at least four compounding problems:
(i) No established market for residential bird-friendly glazing. The glazing specifications in the ordinance were developed for commercial construction. There is no established consumer market for residential bird-friendly glass and no off-the-shelf residential products that satisfy the ordinance’s criteria.

2 Loss, Will, Loss, Marra, Bird–building collisions in the United States: Estimates of annual mortality and species vulnerability, 2014 (the “Smithsonian Paper”), https://repository.si.edu/bitstream/handle/10088/25413/NZP_Marra_2014- Birdbuilding_collisions_in_the_United_States_Estimates_of_annual_mortality_and_species_vulnerability.pdf?sequence=1&i sAllowed=y. The authors reviewed eight prior studies with a total of 92,869 bird collisions and, applying extrapolation mathematics, projected between 365 million and 985 million birds are killed per year by buildings in the U.S. 3 See, e.g., Leroy, Jarzyna, Kell, Acceleration hotspots of North American birds’ decline are associated with agriculture, 2026, https://www.science.org/doi/10.1126/science.ads0871. The authors found that about half of the 261 species analyzed showed significant declines from 1987 to 2021, and a quarter showed accelerating declines. Hotspots of accelerating abundance decline were located in regions with high-intensity agriculture (high cropland area, fertilizer use, or pesticide use). 4 The effort to adopt bird-friendly design regulations presupposes a problem with bird-window collisions in Palo Alto, but there are no studies showing the nature or extent of the bird strike problem in Palo Alto. Crafting a suitable regulatory framework with incomplete data is at best scattershot. (ARB Member Rosenberg: Feb. 15, 2024 Summary Minutes, p.19; Feb 15, 2024 Video Timestamp 3:28:29; Jul 18, 2024 Summary Minutes, p.17; Jul 18, 2024 Video Timestamp 3:44:49; ARB Member Baltay: Feb 15, 2024 Summary Minutes, p.19-20; Feb 15, 2024 Video Timestamp 3:34:25; Jul 18 Video Timestamp 3:54:47.)
5 Requiring bird-friendly glazing on residential buildings, particularly single-family homes, would be extremely onerous due to its special-order-only availability. Consequently, it would frustrate efforts to increase housing production. (ARB Member Hirsch: Jul 18, 2024 Summary Minutes p.18; Jul 18, 2024 Video Timestamp 3:55:32; ARB Member Adcock: Feb 15, 2024 Video Timestamp 3:31:57; Jul 18, 2024 Summary Minutes p.18; Jul 18, 2024 Video Timestamp 3:52:14; ARB Member Baltay: Feb 15, 2024 Video Timestamp 3:34:25; ARB Member Rosenberg: Feb 15, 2024 Video Timestamp 3:28:29.) Honorable Mayor and Members of the City Council
March 11, 2026

Page 3 ends

(ii) High cost of commercial-rated glazing customized for residential use. Adapting commercial bird-safe glass to residential applications requires custom fabrication at costs disproportionate to residential project economics, raising serious feasibility concerns. (iii) Design constraints and aesthetic impacts. Commercial fritting patterns and glazing specifications impose design and aesthetic constraints that conflict with residential architectural norms6 and resident expectations.7
(iv) Environmental and sustainability concerns with non-permanent alternatives. Non- permanent markers and films raise unresolved environmental and sustainability concerns regarding adhesive materials and long-term durability that the ordinance does not address.

These are not hypothetical concerns. They reflect the real-world gap between criteria developed for large-scale commercial construction and the requirements of residential development, a gap the ordinance has not addressed and that cannot be closed simply by making commercial-grade criteria mandatory.

III. A Practical Path Forward: Voluntary Guidelines
The Comprehensive Plan’s authorization of guidelines is the right instrument for this stage of the City’s engagement with bird-friendly design in residential construction. In lieu of the proposed ordinance that exempts most residential homes, we recommend the following course of action:

Adopt non-mandatory bird-friendly design guidelines. Direct staff to prepare and adopt guidelines consistent with Program L6.3.1’s authorization. Those guidelines would be applicable to all discretionary projects — commercial, institutional, and residential — through the City’s architectural review process, reaching the substantial majority of new construction in Palo Alto.

Voluntary uptake under design review, combined with staff encouragement and public outreach, can generate meaningful real-world experience with residential bird-safe design in this community.

Obtain Palo Alto Bird Collision Studies. Partner with local environmental organizations to monitor and evaluate the voluntary implementation of the guidelines over time — tracking which measures are adopted, at what cost, with what design impacts, and with what observable effect on bird collision rates in Palo Alto. This localized evidence base, rather than extrapolations from generalized data, should inform any future decision about whether mandatory requirements are warranted and, if so, what form they should take.

Once specific problematic buildings or building features are identified, adopt restrictions.

If the studies ultimately demonstrate that specific residential mitigations deliver meaningful benefits at feasible cost, the Council will be in a position to put in place mandatory standards and bring forward a revised ordinance grounded in locally validated, residentially appropriate

6 Glazing as a percentage of floor area for residential energy efficiency purposes is already calculated, but measuring glazing as a percentage of each elevation in the context of residential development would add significant design costs, not to mention Planning staff time required to check each calculation. (ARB Member Baltay: Jul 18, 2024 Summary Minutes p.19; Jul 18, 2024 Video Timestamp 4:05:27; ARB Member Adcock: Jul 18, 2024 Video Timestamp 4:05:43.) 7 In circumstances where the only outdoor views for residents are through their bedroom windows, such as in long-term care developments, bird-friendly windows would not be a “pleasant” experience for those residents. (ARB Member Chen: Jul 18, 2024 Summary Minutes, p.18; Jul 18, 2024 Video Timestamp 3:56:12.)

Honorable Mayor and Members of the City Council
March 11, 2026

Page 4 ends

criteria. Coincident with a conforming amendment to the Comprehensive Plan, that ordinance will be both legally defensible and substantively justified.

IV. Conclusion
Forcing a solution to a perceived problem without supporting data is not good stewardship of the City. The increased housing development costs and delays would be material, as the Architectural Review Board found. Nonetheless, if the Council desires to force a solution coincident with a conforming amendment to the Comprehensive Plan, the PTC’s recommended approach, which excludes most residential properties except portions over 35 feet high, is a reasonable pathway as it attempts to balance burden and benefit in the absence of data.

Respectfully submitted,

EDGEWOOD NEIGHBORHOOD ALLIANCE
By, its representative,

Jeffrey Shore
cc: Matthew D. Francois, Rutan & Tucker, LLP
David Lanferman, Rutan & Tucker, LLP
Jonathan Lait, Director of Planning & Development Services Jennifer Armer, Assistant Director of Planning & Development Services Kelly Cha, Senior Planner
Ed Shikada, City Manager
Caio Arellano, Interim City Attorney

Palo Alto City CouncilMarch 16, 2026

Palo Alto City Council
March 16, 2026