CGF journal

Observations and thoughts from Committee for Green Foothills.

Monday, June 1

Rescuing "sustainability" from the vaccuum of meaninglessness

(Below is a piece I submitted to the KQED Perspectives program about the Stanford Sustainable Development Study. Unfortunately they thought the focus was too narrow for the broader Bay Area, but I still think it's worth getting the word out. -Brian)


Everyone talks about "environmental sustainability," but do we know what it really means? Claims of sustainability may amount to little more than greenwashing, with no more content or definition to them than being "Earth-Friendly".

This problem has happened in Santa Clara County, with an unfulfilled promise made by Stanford University. In return for massive development rights, the university promised a Sustainable Development Study to consider the sustainability of future buildout on its core campus land. Stanford recently turned in its Study and the County approved it.

The problem? Stanford refused to study the effect of buildout for more than twenty-five years into the future. But sustainability, if it means anything at all, can't ignore the effects beyond a single generation. Climate change, for example, would drop considerably as a priority if, like Stanford, we refused to consider development and consequences for more than twenty-five years. Stanford might not want to consider long-term sprawl effects, but is a short time frame sustainable?

These aren’t questions about an academic exercise but about the essential meaning of sustainability. Here's how little importance Stanford placed on sustainability – they refused to even define "sustainability" in their Sustainable Development Study. Good definitions exist – just ask former Stanford professor and Obama science advisor John Holdren – but here the long-term timeframe of sustainability definitions lost out to the desire to leave the door open for expanding development.

Being "Earth-Friendly" may now mean almost anything, but we can still rescue sustainability. For example, Stanford did accept that it would do another Sustainable Development Study for its next major permit. Next time, Stanford's famed academic rigor could be applied to the Study itself, with sustainability defined, with measurement criteria included, with performance analyses developed, and with defensible conclusions about the long-term sustainability of its land use. The next Study can still do it right.

If the concept of sustainability is itself going to be sustained, we must give it meaning, and we can't start too soon.

With a Perspective, I’m Brian Schmidt.

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Thursday, April 30

Stanford Sustainable Development Study: document dump

I normally try to post most of my written communications here on the blog. In the case of the Stanford Study, much of that didn't happen due to everything going on. Below the fold are a few of the things I wrote during that time:



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(A short PowerPoint presentation on the failure to define "sustainability")











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(More on what should have been included)
Principles for a new chapter in the Stanford Sustainable Development Study regarding the Academic Growth Boundary and Stanford's future after 2035

Academic growth needs:
While acknowledging that significant increases in Stanford's population and square footage beyond that discussed in the Study's Scenario C could have environmental impacts on issues such as transportation and greenhouse gas emissions, an equivalent or greater amount of development than Scenario C could be added after 2035 without fundamentally and negatively altering the character of Stanford's core campus. There is therefore no foreseeable academic need for expanding development beyond the AGB.

Additional issues regarding sustainability and the AGB:
As Stanford increases in population and square footage, the need for nearby, accessible open space also increases.

As Stanford increases in population, the people brought to the area by Stanford will make increasing use of open space lands not owned by Stanford. Any reduction of Stanford's open space by expanding beyond the AGB would exacerbate the environmental impact on non-Stanford land.

Environmental benefits such as public transit and walkability increase through concentrating Stanford development within the AGB as opposed to expanding the existing the AGB.

Long-term conservation biology projects are in place in the Stanford Foothills and could be harmed or destroyed by expanding the AGB.

Stanford's proposed 50-year Habitat Conservation Plan also relies on protection of much of the Stanford Foothills.

The Stanford Research Park and Stanford Shopping Center areas are Stanford-owned land that are not being used for its core academic mission and could be converted back to academic work rather than encroach upon the Stanford Foothills.

Online distance learning provides a significant avenue for potential growth for Stanford while avoid many environmental impacts, including impacts on open space.

Conclusion:
There is no foreseeable academic need to expand beyond the AGB after 2035, and environmental principles for making Stanford University a sustainable community make maintaining the existing AGB even more important as development continues at Stanford. This Study concludes for the foreseeable future after 2035, the Academic Growth Boundary should not be changed.

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(Still more on what should have been included)
Should describe what sustainable development would look like

Should describe constraints on development:
Water
Sewer
Energy
Energy transmission
Greenhouse gas emissions
Other pollutants
Waste generation
Hazardous waste - full life cycle
Development density relative to surrounding communities

Should describe to what extent, if at all, Stanford's development would need to go beyond the Academic Growth Boundary for the foreseeable future.
Should describe the relationship between open space and increased development
Should describe alternatives to extending into the foothills, including converting Stanford Research Park and Shopping Center back to core mission
Should describe the role of online study

Should describe what is the likely cap on overall development
Should describe role of satellite campuses, off-site offices, and effect on overall sustainability
Should describe the relationship between increased development and increased traffic, and the traffic's effect on sustainability

Should describe other indicators of sustainability
Should indicate whether the intent is enough housing for all people studying and working on campus, including affordable housing
Should describe conservation biology goals for areas beyond the AGB for the foreseeable future, including but not limited to the habitats and time frame of the Stanford HCP
Should describe the relationship between new development and compliance with AB 32 and SB 375 and their likely successors for the foreseeable future (could be done by describing role in County's compliance or by analyzing as if the laws applied to Stanford as a separate entity).
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(My notes when I prepared to speak at the April 7, 2009 hearing)
2035 is only ten years past the expiration of the existing 2025 Academic Growth Boundary at Stanford. Should we care about what happens after 2035?


Is it possible to plan past 2035? Stanford thinks so.


How can anyone plan beyond 25 years? Different levels of specificity
(and remember non-binding)


Would it do any good to make extend this study past 2035? It would influence the next General Use Permit and the next Sustainable Development Study if it did extend longer. So long as Stanford keeps thinking in the back of their heads that "the phase after this next one is when we make the Foothills look like the core campus," then they won't commit to planning the foothills for permanent low-impact outdoor recreation, low-impact studies, and conservation biology projects. Extending the Study period outward, together with the next Study, would help shake off that mindset.

Finally, the Committee strongly urges the Supervisors NOT to take the approach of letting Stanford off with something inadequate now under the idea that they'll be held to a higher standard next time. Frankly, we've heard that before regarding Stanford's environmental commitments and it will happen again in the future if it's not stopped. The next Sustainable Development Study, for example, can be improved by developing it simultaneously with the next General Use Permit, but that shouldn't let Stanford out of its current commitment. The current Study should be rejected until extends closer to what Stanford promised, or at least significantly past 2035.
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(County staff responded here to numerous examples showing the legislative history of the Study meant it to have an indefinite or 99-year timeframe. Below is CGF's reply.)

I had overlooked that staff's Attachment G enumeration of the legislative history citation also contained something of a response.
Going through them briefly:
#1. Palo Alto's letter: Staff ignores the key term in the Palo Alto letter, that the vision should describe the "ultimate buildout" of the campus. That became the "maximum planned buildout potential". It's how the concept originated, and they're ignoring it because the term "ultimate" is inconvenient for their interpretation.
#2. Menlo Park: less important, but still an indication that the non-binding Study was to substitute for a lack of permanent protection, and a ten-year extension doesn't fit that role.
#3. Simitian written comments: he puts the terms together. Contra staff's earlier statement in its attachment, the Sustainable Development Study combines Beall's suggestion of such a study with Simitian's suggestion of a Buildout Study. Simitian wrote this one month before he made the motion that made the Study part of the GUP.
#4. Transcript of hearing: staff incorrectly says the concept of clustering credits was abandoned. Instead the only two Supervisors who spoke on the subject of the contents of the Study said that credits "can be looked at in the Sustainable Development Study". It would be nonsensical to look at credits for a study that extends the Academic Growth Boundary for only ten years, so I can't see how to avoid concluding that the staff's interpretation is that the Supervisors were being nonsensical. We disagree.

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Thursday, April 16

Stanford Study and thank yous to Santa Clara County Supervisors

(CGF sent the following thank you and suggestion to Supervisors Kniss, Yeager, and Cortese for their resolution that went beyond the staff recommendation of simply approving Stanford's draft Sustainable Development Study. We hope that some years in the future, Supervisors Yeager and Cortese will have the chance to support our suggestion of making a new Study simultaneous with a new GUP. -Brian)


Dear President Kniss, Vice-President Yeager, and Supervisor Cortese:

I would just like to thank you all (somewhat belatedly) on behalf of the Committee for Green Foothills for your work on the Stanford Sustainable Development Study and the resolution that you passed. While more could always be done, and we would like to do more, we also very much appreciate your decision to go beyond what was placed in front of you and to make findings and recommendations that we believe will help direct future development on Stanford lands in a more sustainable direction.

In particular, President Kniss and Supervisor Cortese had a useful discussion that clarified doing another Sustainable Development Study right before or right after the next General Use Permit would be of relatively little use. One idea we would like to explore in the future, however, is that a Study could be developed simultaneously with the next the GUP, just as the EIR for the next GUP would develop simultaneously. The initial, broad outlines of the GUP proposal could direct the initial framework of both the EIR and the Sustainable Development Study. If at any point the EIR or Study show environmental problems, they could provide feedback that would help redirect the GUP proposal in a more environmental benign and sustainable direction. The EIR process can work this way, so there is no reason why a Sustainable Development Study can't as well.

President Kniss is quite correct that the next GUP will likely occur after her term in office, but both Vice-President Yeager and Supervisor Cortese may have the chance to help direct it. The Committee for Green Foothills will be happy to provide any assistance.

Thanks again.

Sincerely,
Brian Schmidt
Legislative Advocate, Committee for Green Foothills

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Monday, April 13

Shoulda, coulda, woulda - the Stanford Sustainable Development Study

Well, it may not be surprising, but it's still disappointing that Santa Clara County didn't require Stanford to do an adequate job on it's Sustainable Development Study. The Study was an important requirement of the 2000 General Use Permit that Stanford mostly dismissed with a recitation of ongoing campus programs rather than an analysis over whether the campus is on a sustainable path. The main problem, besides the lack of real analysis, was an artificially-short 25 year time frame that makes it impossible to consider whether an existing trend has a long-run impact. We've covered this at various times on our website, beginning here and in some detail here.

The Supervisors did vote for a few findings and recommendations for future improvements that the Board of Supervisors could use someday, when Stanford exhausts its current General Use Permit. These will have some value in instilling the concept of sustainability in future environmental planning, although it should have been done now.

Unfortunately, only three of the five Supervisors supported even these findings and recommendations, but we do thank Supervisors Kniss, Yeager, and Cortese for doing so. We at the Committee especially appreciate President Kniss and her aide Scott Strickland for their efforts at improvements.

So whenever things don't go as well I'd like, I always think of what I should have or could have done better. In this case it was trying to get the Supervisors to require a future Sustainable Development Study be developed simultaneously with the development a future General Use Permit, which would help redirect the Permit in a more sustainable direction. I think the Supervisors missed the idea of simultaneity. All I can say now is that we can try again to make that happen when the next Permit rolls around.

I'll add some follow-up posts that will take care of some old business on this issue during the week. We especially thank everyone who wrote into the Supervisors and asked for the improvements. We got something out of it, and we're ready for next time.

-Brian

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Wednesday, January 14

CGF comments at today's San Mateo County Planning Commission

(Not sure how useful this will be, but Lennie and I testified at today's San Mateo Planning Commission about Stanford's inadequate Sustainable Development Study. Attached below are my notes, improved somewhat so others might understand them. I think we had some success persuading the Commission and maybe staff. -Brian)


Primary disagreement with staff - 25 year limitation on analyzing sustainability

Question is whether this fully complies with what Stfd promised, and if not whether SM county should be interested in promoting compliance

Not just a check-off box - Stanford MUST submit an adequate plan to continue new development

Two problems with the non-compliance – nowhere in the permit plan or admin record was the study limited to a restricted time frame – a lot of info suggests otherwise

Second, that by definition you can't do an adequate sustainability study while limiting it to a short time frame like 25 years

No definition was included – page 94

Here's a def they could use:
"A sustainable process or condition is one that can be maintained indefinitely without progressive diminution of valued qualities inside or outside the system in which the process operates or the condition prevails."

No criteria for measurement, analysis, or conclusions re sustainability

Just one example of effects on SM County – traffic impacts from development post-2035

Can you analyze beyond 2035 - yes, two examples

Not sure about your process – I suggest you recommend letter not go forward as written

Analogy - Alpine Road sidewalk expansion also failed to meet Stanford's original promise

Encouraged by Joe Stagner's reference to planning to 2050

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Wednesday, December 10

Cover email sent regarding Stanford Sustainable Development Study

(An earlier post summarizes information showing the Stanford Sustainable Development Study was meant to cover the foreseeable future for at least 99 years. Below is an email we sent to the Palo Alto City Council along with the summary info. -Brian)

Dear Palo Alto City Council Members,

Sometime early next year, you will have the chance to comment on the draft Stanford Sustainable Development Study, which must be approved by Santa Clara County before Stanford can apply for the second million square feet of development. The draft submitted by Stanford violates the Stanford Community Plan because it describes planning for buildout only ten years past the existing, 25-year restriction on expansion beyond the Academic Growth Boundary. The Community Plan calls for a description of the "maximum planned buildout potential" that has always been understood to apply to the foreseeable future far beyond the additional ten years proposed by Stanford. The City of Palo Alto made this its own official policy in 1999, and we ask you to strongly reaffirm this position when the issue comes before the City Council.

To understand the planning horizon contemplated in December 2000 for the Stanford Sustainable Development Study, the Committee for Green Foothills has done a preliminary review of documents that formed the origin of the Stanford GUP requirement for the Study. The first attachment is our summary and is reprinted at the bottom of this email; the subsequent four documents contain one or more additional sources.

All the relevant sources that we found support the idea that the planning horizon for the Study is either permanent or at least for 99 years, which we equate with planning for the foreseeable future. We found no support in the record for the Stanford's contention that the Study was meant to have a planning horizon that extended only 10 years past the 25-year limit protecting the Academic Growth Boundary.

We would be happy to answer any questions.

Sincerely,
Brian Schmidt

Brian Schmidt
Legislative Advocate, Committee for Green Foothills

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Thursday, December 4

Stanford Study meant to be permanent or at least 99 years

(The following document on the Stanford Sustainable Development Study was sent to multiple government officials today. -Brian)


Excerpts of statements in the administrative record for the December 2000 Stanford GUP that are related to the planning horizon for the Stanford Sustainable Development Study


City of Palo Alto recommendations of 10/12/99, reaffirmed 10/25/99 and 10/28/99:

Vision for Long-Term Build-out of Stanford University

· The Community Plan should include a long-term vision, beyond the 10-year scope of the Plan, for the ultimate build-out of the University. While it is recognized that this vision would not be as detailed as the ten-year Plan regarding Stanford's potential development, it would be helpful I providing insight into the University's future evolution.

Note: the call for "vision" for "ultimate build-out" was expressly reaffirmed in the later City documents. The ten-year reference for the current Plan was based on an expected fast buildout under the Stanford GUP. "Ultimate build-out" excludes Stanford's suggestion that Study only covers 10 years more than the Academic Growth Boundary protection to the year 2025.


City of Menlo Park recommendations of 10/21/99, reaffirmed by the City on 1/5/00:

The Community Plan should have both a total and permanent limitation, or cap, on building square footage and population with the understanding that it does not give Stanford the right to extend the limits beyond the cap.

Note: Menlo Park felt the permanent cap should be both mandatory and part of the Stanford GUP, so interpreting the Study to only add ten years of planning would not support the City's comments.


Written statement by Supervisor Joe Simitian of 10/24/00:

During the past 18 months some members of the public have proposed that we use this GUP and Community Plan process to establish a "cap" on the University's maximum development potential, "buildout" as it's often referred to....I am not inclined to propose that our Board establish a permanent cap or attempt to define at this point the ultimate buildout of the campus.

I am inclined to think, however that it would be irresponsible to simply ignore the need for a clearer notion about the ultimate capacity of Stanford lands and a clearer vision of what such a plan might entail. For that reason I'm inclined to suggest to my colleagues that the Conditions of Approval for the GUP include a condition requiring that Stanford undertake a Buildout Study regarding the buildout potential of Stanford University on all unincorporated lands within Santa Clara County.

Note: Here the then-Supervisor Simitian made synonymous the terms "cap," "maximum development potential," "ultimate capacity of Stanford lands," and "Buildout Study". The Buildout Study was later renamed the Sustainable Development Study.


Statements by Supervisors Simitian and Beall at the Stanford GUP hearing of 11/27/00:

Sup. Simitian:….I had proposed one tool, the use of Clustering Credits which to understate the case dramatically was not well-received by the University…. The question then is how do we deal with this issue of finding a real plan to prevent sprawl that is acceptable and manageable for all the parties involved, and what I would suggest is that…prior to the second million square feet of academic facilities being constructed and permits being issued, that the University be obliged to prepare a Sustainable Development Plan which would address these issues to the satisfaction of the Board….[I]t would in effect say okay, apparently Supervisor Simitian's suggestion for dealing with the issue of sprawl was something the University found unacceptable but now we'll give it to the University and give them the chance to say here's how they'd like to address the issues of sprawl….

Sup. Simitian:….Why don't we just indicate for the record that those five items [including Sustainable Develoment Study] are in lieu of the Clustering Credit language which was submitted originally in the Community Plan….

Sup. Beall: I think the general idea of clustering is something we're not abandoning….

Sup. Simitian: Right, I, whether or not clustering or rather clustering credits live to see another day is an open question, and it's certainly something that can be looked at in the Sustainable Development Study that Supervisor Beall and I have both referenced….

(Emphasis added.)


Note: Clustering credits had been proposed by environmental groups to give Stanford the ability to develop a certain amount in the core campus in return for permanent Foothills protection, while Supervisor Simitian proposed them for 99-year protection. There would be no point in considering them in the Study if the Study's planning horizon is only 10 years longer than the Academic Growth Boundary Protection that was being proposed at the time.


The Committee for Green Foothills has all the relevant documents and transcripts. We found nothing in any of the documents we studied to support the idea that the Study was meant to have a planning horizon short of permanent or 99-year time frame, which we would consider comparable to planning for the foreseeable future. Stanford's attempt to reduce the scope of the Study can only be done, if at all, through a General Use Permit amendment, and not through non-compliance.


Please contact Brian Schmidt (650) 968-7243 with any questions.

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Wednesday, November 26

Timeline for Stanford Sustainable Development Study

CGF Intern Laurel Smith and I have been researching how the Stanford Sustainable Development Study became a requirement in the 2000 General Use Permit, which will hopefully help shed light on the question of whether the "maximum buildout potential" meant "maximum buildout potential" or if it meant "maximum buildout up until some relatively short period in the future, and then all bets are off."

First thing we've found so far is a statement by then-Supervisor Joe Simitian on 10/24/08 on County letterhead:

During the past 18 months some members of the public have proposed that we use this GUP and Community Plan process to establish a "cap" on the University's maximum development potential, "buildout" as it's often referred to....I am not inclined to to propose that our Board establish a permanent cap or attempt to define at this point the ultimate buildout of the campus.

I am inclined to think, however that it would be irresponsible to simply ignore the need for a clearer notion about the ultimate capacity of of Stanford lands and a clearer vision of what such a plan might entail. For that reason I'm inclined to suggest to my colleagues that the Conditions of Approval for the GUP include a condition requiring that Stanford undertake a Buildout Study regarding the buildout potential of Stanford University on all unincorporated lands within Santa Clara County.

So from the beginning, "cap" = "maximum development potential" = "ultimate capacity of Stanford lands" = "Buildout Study". The Buildout Study was later renamed the Sustainable Development Study.

The next thing we found in November 2000 was tying the Buildout Study to the Compact Urban Growth standard that would've limited growth beyond the Academic Growth Boundary for 99 years. That time period limitation later shrank to 25 years.

Still later, November 22, 2000, then-Supervisor Beall proposed the new name, "Sustainable Development Study" that broadened the scope of the Study somewhat. While somewhat unclear from the document I've got, he may also have inserted the Community Plan language "it would be infeasible to accommodate an additional 200,000 square feet annually in perpetuity, in is unclear how much additional development is appropriate." This is a statement about the foreseeable future with no end date. The Study is supposed to address the question of "how much additional development is appropriate" without an end date.

The final change follows a letter from just-elected-to-the-Assembly Joe Simitian, requesting the term "maximum buildout potential for all fo Stanford's unincorporated land" be placed in the Stanford Community Plan, explaining that the concept was part of the conditions for the General Use Permit. The term went in.

Nothing suggests the idea ever restricted the vision from the original idea of determining the ulitmate capacity of the land for the forseeable future.

-Brian

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Tuesday, November 25

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.

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Tuesday, November 11

Draft Stanford Sustainable Development Study available, and there are problems

Stanford's long-promised, draft Sustainable Development Study is available here. While I haven't had the time to take a good look at it, there's an immediately-obvious flaw - it's supposed to "identify the maximum buildout potential and all areas of potential development" but fails to do that, instead describing what buildout is expected only through 2035.

This issue alone is going to take a lot of work to get right. We'll have to take a close look at the rest.

-Brian

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