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 of the Draft Bird-Friendly Design Ordinance adding Section 18.40.280 to the Palo Alto Municipal Code as proposed in Attachment A.
Palo Alto residents consistently express strong support for protecting nature, biodiversity, and wildlife habitat, as reflected in City policies such as 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 of migratory and resident birds.
The Draft Ordinance defines Bird Sensitive Areas in the Baylands and the foothills (east of Highway 101 and west of Foothill Expressway). Outside of these Bird Sensitive Areas, the ordinance does not apply to any existing, modified or new portion of residential structures under 35 feet.
Routine window replacement does not automatically trigger bird-friendly treatment requirements unless the glazing would otherwise trigger a building permit and falls into the hazard categories defined in the ordinance. Therefore, the ordinance does not apply to most replacements of fenestration. We would have preferred stronger requirements for new residential development and major remodels in order to avoid creating new hazardous architectural elements, but we recognize that this ordinance has undergone extensive review by 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 as proposed.
Staff recommends that the City Council consider extending the 35-foot height exemption universally to all development types. It is 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 as this would significantly weaken the ordinance and create a very low benchmark for other jurisdictions to follow. As pointed out above, most collisions occur at tree-canopy height, from ground level to roughly 60 feet.
Alternatively, Staff recommends expanding the allowance of films and decals for non-residential projects, an option supported by local businesses in order to provide a more affordable compliance option when specialized glazing is cost prohibitive.
If Council wishes to extend the allowance of films or decals to non-residential projects, we ask council to direct the ordinance to limit these installations to products that are approved by the American Bird Conservancy, and require the installation to be on 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 in 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