October 28, 2025
To: Brenda Sylvia,
Assistant Community Services Director
City of Mountain View
Re: City of Mountain View Biodiversity & Urban Forest Plan
The Santa Clara Valley Bird Alliance, Green Foothills, the Sierra Club Loma Prieta Chapter and the Native Plant Society Santa Clara Valley Chapter commend the City of Mountain View for developing an exceptionally thoughtful and well-researched Biodiversity & Urban Forest Plan. This Draft Plan represents a significant advancement in how cities can integrate best-available science, historical ecology, climate resilience, and community values into a cohesive and forward-looking roadmap. It is clear that substantial care and expertise went into this work, and the City can be proud of the scientific rigor and holistic approach reflected throughout the document.
We appreciate that the Plan is not entirely anthropocentric. It is refreshing to see a Vision that recognizes the city as a shared environment for both people and native species, rather than focusing solely on human benefits. This positions Mountain View as a leader among cities acknowledging that human wellbeing and ecological health are interdependent. The Plan’s strong scientific foundation offers a meaningful roadmap that, when implemented, will strengthen the interconnected health of people, nature, and the broader environment.
With this strong foundation, we believe that there are some additions that would further strengthen the Plan, so we offer the following comments and recommendations.
Structure from Vision to Implementation
The Plan clearly explains how the Vision will translate into Goals, Objectives, Actions, Metrics, and Targets. To support successful delivery, it will be important that implementation details do not remain deferred.
Implementation and Accountability
The Plan acknowledges it does not include cost estimates, staffing, or timelines, which will be defined later. Without at least a preliminary roadmap of “early wins,” resourcing needs, and departmental roles, implementation may stall. We recommend the development of a Companion Implementation Strategy to be adopted concurrently to ensure accountability. Biodiversity actions will span multiple departments (e.g., Public Works, Community Services, Planning, Shoreline), so a brief outline of roles would improve clarity. Since nearly 90% of tree canopy is on private property, expanding incentives, partnerships, and education for private landowners will also be essential. Consolidating metrics, public reporting, and adaptive management into the Implementation Strategy will help maintain transparency and allow the City to adjust course as needed.
Resolving inherent tensions
The Plan makes a strong case for the connection between ecological health, human wellbeing, and climate resilience. We also appreciate the honest discussion of trade-offs between planting locally native species that support biodiversity and selecting climate-adapted species. We strongly believe that climate-forward planting must not outpace the native fauna’s ability to adapt; survival of trees is not equivalent to survival of ecosystems.
Most native insects, forming the base of the food web for birds, amphibians, and other wildlife, have co-evolved with local plant species and cannot use non-native plants or native plants from other regions of California for food or reproduction. A shift toward climate-resilient non-native or non-local trees risks creating a canopy with low habitat value. To strengthen this section, we recommend a clear decision-making framework that places greater weight on locally native plants wherever feasible. Establishing a simple decision matrix that favors regionally native shrubs and trees where habitat benefits matter most, and uses non-native species only where absolutely necessary, would support more consistent, biodiversity-driven decisions.
Biodiversity Ambassadors
We appreciate the use of Biodiversity Ambassadors to make the Plan relatable and show how actions benefit real local species. However, it is not clear how these will be used. Will they inform educational programs, metrics, or community science tracking? Linking Ambassadors to specific actions or indicators would increase their value. For example, planting Valley Oaks in clusters could support Acorn Woodpeckers, and increasing native willow groves and other insect-supporting plants along creek corridors could benefit Wilson’s Warblers during migration. A notable gap is the absence of a nocturnal species, despite later discussion of light pollution. Including a bat or Great-horned Owl would create a direct link to nighttime habitat needs.
We also have the following specific suggestions:
Section 3: Landscape Assessment and Policy Overview
3.1 Biodiversity Assessment
The use of SFEI’s Urban Biodiversity Framework (7 elements) is excellent. It is science-based and comprehensive, and the analysis clearly shows gaps and opportunities across the landscape (matrix quality, patches, connections, native vegetation). Some terms (e.g., patches, matrix, core area) may be too technical for general audiences; a brief plain-language “Quick Guide” could help. The Plan could also identify priority pilot sites for early biodiversity gains, such as “Top 3 sites for near-term patch enhancement” or “Top 5 connection barriers to address first.”
Throughout the Plan, the term “native” is sometimes used without specifying whether it refers to California native or regionally native species. Because ecological benefit varies significantly between the two, we recommend consistent and explicit use of these terms.
3.2 Urban Forest Assessment
We appreciate the Plan’s analysis of native, non-native, and invasive trees, as well as the distinction between public and private trees. With only 14.7% of public trees native to California or the Bay Area, and nearly 90% of canopy on private land, meaningful progress cannot rely on City-led plantings alone. Increasing the proportion of regionally native trees, especially oaks, willows, maples, sycamores, and buckeye, should be a stated priority, as these species are critical for supporting native insects, which form the base of the food web for birds, bats, and other wildlife. Most urban biodiversity depends on local native shrubs and understory plants, not only trees, as these plant layers provide forage, nesting, and shelter, and this priority should be clearly stated rather than implied.
It is also concerning that 9.1% of public trees are identified as invasive. We encourage a phased removal and replacement plan, prioritizing species with the greatest ecological impacts, paired with expanded private-property engagement to support habitat-rich landscaping.
We recommend the following.
Establish a target to increase regionally native tree representation across the urban forest over time.
Prioritize regionally native species in planting lists, particularly in parks, schools, riparian areas, and residential streets.
Develop a phased approach to replace invasive species with regionally native or non-invasive, climate-appropriate species.
Expand strategies to engage private landowners, including residents, HOAs, schools, and businesses, in planting and maintaining regionally native trees and habitat-supportive landscaping.
The box on page 37 of the plan highlights opportunities for the City to influence the private sphere of its urban forest. Please consider adding regulations, new ordinances and updating ordinances to the palate of opportunities to strengthen the urban forest and biodiversity.
Section 3.3
This section provides useful context on existing policies and regulatory frameworks. To strengthen alignment with current habitat and wildlife conservation efforts, we recommend that the Burrowing Owl Preservation Plan and the Shoreline Wildlife Management Plan be formally integrated by reference into this document.
Section 5: The Plan – Charting the Path
This section is critical to ensuring that the Plan moves from vision to effective action. The Goals, Objectives, Actions, Metrics, and Targets provide a solid framework for guiding progress.
5.1 Implementation: Vision to Action
To avoid the risk of the Plan becoming aspirational rather than actionable, the City should develop a formal Implementation Plan to accompany or follow this document. Many actions are currently framed as optional (e.g., “encourage,” “consider,” “where feasible”). Clarifying which actions are mandatory for City projects and where flexibility is appropriate will help ensure biodiversity outcomes are not left to interpretation.
We recommend
Defined timelines or phases for implementation.
Identification of lead and supporting departments for each action.
Anticipated resource needs (staffing, funding, expertise).
A process for updating actions as new science and climate projections evolve.
5.2 Evaluation: Metrics and Targets
Metrics and targets are essential, but they must be clear, measurable, and publicly reported. We recommend
Establishing a regular public reporting process (annual or biennial).
Including baseline conditions and target dates.
Ensuring metrics assess outcomes as well as actions - for example, measure increases in native habitat or species presence.
Incorporating adaptive management to allow the City to course-correct based on results.
5.3 Next Steps
The “Next Steps” section offers an opportunity to build early momentum. We recommend the following early actions within the first 12–24 months.
Adopt native-first planting standards for City projects, with explicit emphasis on locally native shrubs and understory plants.
Initiate and support habitat pilot projects in parks, creek corridors, or other public spaces.
Provide staff training on biodiversity-supportive practices.
Establish public reporting of metrics to maintain accountability.
Launch a private-property program to incentivize native trees and habitat landscaping.
Begin a phased replacement of invasive tree species, prioritizing those with the greatest ecological harm.
Guide A: Urban Landscaping and Biodiversity
Guide A provides useful direction for incorporating biodiversity into landscaping; however, to deliver meaningful ecological benefit, it should place stronger emphasis on locally native shrubs and understory plants, not only trees. Most urban biodiversity depends on these plant layers for forage, nesting, and shelter, and this priority should be clearly stated rather than implied.
We recommend that Guide A
Clearly prioritize locally native shrubs, perennials, and groundcovers as core components of habitat-supportive landscaping.
Specify that City-led projects will follow the Guide and clarify expectations for commercial/corporate development (required vs. strongly encouraged).
Strengthening these elements will help ensure landscaping across Mountain View supports functional habitat and biodiversity.
Guide B: Plant Lists
Guide B is an important tool for guiding plant selection; however, to effectively advance the Plan’s biodiversity goals, the plant lists should more clearly prioritize regionally and locally native species and minimize use of non-native ornamentals with low habitat value. A broad list without clear hierarchy risks perpetuating current landscaping practices rather than shifting them toward habitat-supportive outcomes.
A clearer hierarchy, of locally native first, followed by non-invasive and climate-appropriate native species when necessary, will help ensure that Guide B leads to measurable biodiversity gains rather than reinforcing status-quo landscaping.
We recommend that Guide B
Clearly distinguish regionally native species from non-native species and identify native species as the preferred choice for City projects and recommended for private development.
Include a dedicated list of locally native shrubs, perennials, and groundcovers, not only trees, reflecting the importance of full habitat structure for supporting insects, birds, and other wildlife.
Remove or flag non-native species that offer low habitat value or conflict with biodiversity goals, to avoid their continued default use.
Guide C: Urban Forest Policies and Practices
Guide C provides an important review of the City’s urban forestry policies, ordinances, and operational practices. Because the success of this Plan depends on consistent implementation across City departments and private development, this Guide is critical. We support the recommendations to strengthen regulation, policies, enforcement, and operational capacity. To ensure alignment with the Plan’s biodiversity goals, native-species prioritization and habitat-supportive practices should be more explicitly embedded in policy and operations.
We recommend that Guide C
Ensure that updates to the Tree Ordinance, Heritage Tree protections, and technical manuals explicitly reflect native-first and biodiversity-supportive principles.
Strengthen enforcement mechanisms for tree protection, replacement, and maintenance requirements to ensure consistency and accountability.
Expand staff training and interdepartmental coordination to embed biodiversity-supportive practices in permitting, inspections, and field operations.
Include clear expectations for private development to support biodiversity through tree retention, native plant selection, and habitat-supportive landscaping.
Consider adding: Maintenance and Operations
To ensure lasting ecological benefits, this Guide should more clearly outline maintenance practices that protect wildlife and sustain native plant communities.
We recommend adding guidance to:
Emphasize maintenance practices that protect habitat structure, including careful timing of pruning, mowing, and vegetation removal, to avoid nesting and breeding seasons.
Include guidance on soil health and reduced pesticide use to support native insects and the food web.
Explicitly discourage the use of anticoagulant rodenticides (SGARs and FGARs) in City operations and contractor work. These toxins bioaccumulate and cause secondary poisoning of owls, hawks, foxes, and other predators that are essential to natural rodent control and urban ecosystem health. The City should prioritize integrated pest management (IPM) approaches and support community education to encourage raptors and owls and reduce rodenticide use on private property.
Retain leaf litter, seed heads, and deadwood where appropriate, as these provide essential forage and shelter for urban wildlife.
Incorporate staff and contractor training to ensure consistent biodiversity-supportive maintenance across departments and contractors.
Strengthening Guide C in this way will help ensure that urban forest policies, enforcement, and operations align with, rather than unintentionally undermine, the Plan’s intended biodiversity outcomes.
Guide D: Monitoring and Targets
Guide D is essential to ensuring the Plan results in measurable progress rather than aspirational goals. While inclusion of biodiversity metrics and targets is a strong foundation, this Guide would benefit from clearer expectations for monitoring, public reporting, and course correction.
We recommend that Guide D
Prioritize ecological outcome-based metrics (e.g., increases in native plant cover, insect abundance, or presence of focal species), rather than primarily activity-based metrics such as number of trees planted or events held.
Where metrics track native vegetation, consistently distinguish between regionally native and California native species. Combining these could overstate ecological progress, as regionally native species provide greater value for local biodiversity.
Establish a regular public reporting schedule (annual or biennial) to maintain transparency and public trust.
Clarify baseline conditions and target dates to allow for meaningful assessment of progress over time.
Include a defined adaptive management process so actions can be refined based on monitoring outcomes, new science, and climate conditions.
Consider using Biodiversity Ambassador species as visible indicators for community-facing monitoring (e.g., tracking habitat improvements or seasonal presence), providing an accessible way for the public to understand progress.
Strengthening Guide D in this way will help ensure that monitoring supports learning, accountability, and continuous improvement, and that the Plan remains effective throughout implementation.
We thank you for this formidable effort, and hope to continue to engage as the plan moves forward,
Shani Kleinhaus, Environmental Advocate
Santa Clara Valley Bird Alliance
Alice Kaufman, Policy and Advocacy Director
Green Foothills
Judy Fenerty, Conservation Chair
Native Plant Society Santa Clara Valley Chapter
Gita Dev, Conservation Committee Chair
Sierra Club Loma Prieta Chapter