Lighting Ordinance Update

2026010768

City of Palo Alto

NOE - Notice of Exemption

1/23/2026

1/23/2026

Kelly Cha

City of Palo Alto

Senior Planner

Lead/Public Agency / Project Applicant / Parties Undertaking Project

250 Hamilton Ave
Palo Alto, CA 94301

(650) 329-2155

kelly.cha@paloalto.gov

Citywide

Categorical Exemption

15308

The Project is eligible for a Class 8 environmental exemption because it updates city ordinances to implement "Dark Sky" principles aimed at protecting the environment and reducing light pollution. By mandating full shielding, lower brightness levels, and a color temperature cap of 2700 Kelvin, the regulations minimize disruptions to nocturnal wildlife and migratory birds while lowering greenhouse gas emissions through increased energy efficiency. Existing lighting must comply within one year to mitigate financial impacts on owners, and because the project is a policy update rather than a construction effort, it ensures environmental protection without authorizing any ground-disturbing activities. The City has determined that the Lighting Ordinance Update (Project) is categorically exempt from CEQA under the Class 8 (Protection of the Environment) Exemption. CEQA Guidelines §15308 reads: “Class 8 consists of actions taken by regulatory agencies, as authorized by state or local ordinance, to assure the maintenance, restoration, enhancement, or protection of the environment where the regulatory process involves procedures for protection of the environment. Construction activities and relaxation of standards allowing environmental degradation are not included in this exemption.” The information herein documents the project’s compliance with the exemption in addition to confirming that no exceptions to the exemption, as outlined in CEQA Guidelines §15300.2, apply to the project. Eligibility for Exemption The Project is eligible for Class 8 (Section 15308) exemption because it consists of a regulatory action by the City to assure the maintenance, restoration, enhancement, and protection of the environment. Specifically, the Project updates the City’s existing outdoor lighting regulations to implement “Dark Sky” principles designed to reduce light pollution. The Project strengthens existing regulations to ensure environmental protection by imposing stricter limits on brightness, requiring full shielding, and capping color temperature at 2700 Kelvin. It also includes a provision requiring existing lighting to comply within one year of adoption, designed to minimize the financial impact on property owners. By reducing light pollution and glare, the Project minimizes disruption for nocturnal wildlife and reduces disorientation risks for migratory birds. Additionally, the Project will reduce unnecessary energy consumption and associated greenhouse gas emissions over time with more efficient lighting practices like lighting curfew with timers and motion sensors. In addition, the Project does not relax any standard that would allow for environmental degradation. As this is a policy update via ordinance, the Project does not authorize ground-disturbing activity or physical construction projects. Exceptions to the Exemptions The City is aware that there are six categories or exceptions that preclude the use of Categorical Exemptions, as listed in CEQA Guidelines 15300.2 These categories, followed by the reason(s) the City believes they are not applicable to this project, are as follows: • 15300.2(a) Location. Classes 3,4,5,6 and 11 are qualified by consideration of where the project is to be located—a project that is ordinarily insignificant in its impact may in a particularly sensitive environment be significant. This is not applicable as the Project is exempt under Class 8. Notice of Exemption ? Lighting Ordinance Update City of Palo Alto 15300.2(b) Cumulative Impact. All exemptions for these classes are inapplicable when the cumulative impact of successive projects of the same type in the same place, over time is significant. The Project is a regulatory action designed to reduce light pollution to return the night sky to its natural dark sky to the extent possible. Therefore, implementation of the Project citywide will result in reduction of light pollution and energy consumption over time. Because these impacts are environmentally beneficial, successive implementation will not result in significant adverse environmental impacts. • 15300.2(c) Significant Effect. There are no unusual circumstances creating the possibility that the project will have a significant effect on the environment pursuant to CEQA. As the Project’s primary intent is to reduce light pollution, there is no substantial evidence of adverse environmental impacts. • 15300.2(d) Scenic Highways. A categorical exemption shall not be used for a project which may result in damage to scenic resources, including but not limited to, trees, historic buildings, rock outcroppings, or similar resources, with a highway officially designated as a state scenic highway. This does not apply to improvements which are required as mitigation by an adopted negative declaration or certified EIR. The Project regulates outdoor lighting and does not authorize any physical alterations to scenic resources within state scenic highway corridors. Therefore, it will not damage scenic resources such as trees, rock outcroppings, or historic buildings within a state scenic highway corridor. • 15300.2(e) Hazardous Waste Sites. A categorical exemption shall not be used for a project located on a site which is included on any list compiled pursuant to Section 65962.5 of the Government Code. The Project is a citywide ordinance update and is not a site-specific development on a hazardous waste site pursuant to Government Code Section 65962.5 (Cortese List). Furthermore, the Project does not authorize ground-disturbing activities, such as excavation or grading, that could disturb hazardous materials or expose the public to health hazards. • 15300.2(f) Historical Resources. A categorical exemption shall not be used for a project which may cause a substantial adverse change in the significance of a historical resource. The Project does not propose the demolition or material alteration of any historical resource. Compliance with the ordinance does not require physical changes that would materially impair the significance of a historical resource or cause a substantial adverse change in its significance.