CGF comment letter on Stanford Sustainable Development Study

(CGF submitted this letter last week regarding the Stanford Sustainable Development Study. -Brian)

November 20, 2008

Santa Clara County Planning Commission

Re: Comments on the Sustainable Development Study for Stanford University

Dear Commission Members;

The Committee for Green Foothills (CGF) appreciates the opportunity to comment on the Stanford Sustainable Development Study (Study). While the process used to reach this point has had significant flaws due to the secrecy in its preparation and the failure to involve the broader community from beginning principles, the draft represents a good first effort in covering part of what was supposed to be done with the Study. In particular, Stanford's own acknowledgment that millions of square feet of additional development could occur within the Academic Growth Boundary without expansion into the foothills is a step toward sustainable buildout that preserves open space. The discussion in Chapter 5 of a wider array of environmental strategies also adds to its value.

The fundamental flaw with the Study, however, is the artificial planning horizon of 2035, a restriction that violates the Community Plan and destroys the Study's usefulness. This flaw must be corrected, probably through action by the County. The Stanford Community Plan (SCP) states the Study must "identify the maximum planned buildout potential" and all areas of potential development. SCP-GD 12. The Study seems deliberately written to avoid quoting this language, often quoting or paraphrasing language before and after the term "maximum buildout potential" while failing to use the term anywhere other than a text box on page 18. The term should be the subtitle on the document's front cover.

No time constraint or planning horizon was included in the Community Plan or in the discussion of the Community Plan and General Use Permit. Because the environmental community had advocated permanent protection of lands beyond the Academic Growth Boundary, the Study requirement made sense as a compromise imposed by the Supervisors and accepted by Stanford – the foothills would not be permanently protected, but a non-binding study showing what areas are likely to remain undeveloped would be delineated. This attempt to not even make a non-binding acknowledgment of those areas fits into an unfortunate pattern of commitments by Stanford for permission for millions of square feet of development, followed by a ridiculously cramped interpretation of those agreements.

The fact that the Study does not look beyond 2035 even reduces its value for the next 25 years. We have no doubt that an adequate Sustainability Study would emphasize that Stanford will need open space indefinitely, that the need will increase as development increases on the core campus, that impacts on surrounding communities from Stanford's growth further justifies open space protection, and that concentrating development on the core campus is more sustainable than spreading it over undeveloped open space. Given that an adequate study would assume no development in the foothills, only by assessing the total level of development that is likely to occur in the core campus could the study also assess how the proposed development in the next 25 years fits into that context. If the development discussed in the draft Study uses almost all the square footage that could be sustainably built in the core campus, then it is likely not sustainable because it leaves little room for later growth. In other words, the draft Study fails to measure full buildout as required past 2035, and also fails to adequately measure sustainability before 2035.

An additional flaw in the Study is a failure to define the parameters of sustainable development in order to determine whether the discussed buildout is sustainable. The section titled "Sustainability Defined" on page 94 fails to include a definition of sustainability. This is unsurprising in a way, because any reasonable definition would not say that sustainable development can ignore any consequence occurring after 2035.

A better draft Study should have a definition of sustainable development; application of the definition to developing parameters for Stanford; a constraints analysis that includes value of open space, resource limits, and relationship of development to surrounding communities; and a scenario range that would weigh potential buildout levels to the sustainability parameters. The task of the County should be to transform the current draft into what the Study should be.

There are many specific comments that CGF has on an adequate Study, but these comments focus on the broader principles of content and process that need to change as we move forward. Fortunately, there is plenty of time. There appears to be no likelihood that Stanford would apply for development beyond the one-million feet ceiling anytime in 2009, with Stanford publicly signaling that it will pull back on new capital projects. In addition, CGF and Supervisor Kniss have called for work to begin on the Study over seven years ago, so any remote chance of delay to Stanford construction projects come down to Stanford's choice of timing to work on the Study.

On process, there should be a series of on-campus and off-campus workshops to develop criteria for the second draft of the Study. These workshops should be led by a County-chosen consultant at Stanford's expense, a provision that Stanford has agreed to. See SCP-GD (i) 3. The organizations mentioned in Study Chapter 5 should be engaged publicly and to the full extent those organizations wish, as opposed to quiet discussions with selected individuals. Elected student, faculty, and alumni association governments should be consulted. The second draft should then be constructed by the County's consultant, with the assistance of Stanford. A projected deadline of summer 2009 for the second draft and fall 2009 for the final version would be appropriate

Specific commentary on content could also be submitted as the workshops and second draft are developed. This first draft is an excellent start. CGF will be happy to submit comments during that process, and can also submit specific comments on improvements for the current draft that could be used in the second draft.

We look forward to participating in a process that protects the local environment and fulfills Stanford's obligation to the community that Stanford agreed to in the Stanford Community Plan.

Please contact us if you have any questions.