If Stanford wishes to further its development, the university must be held accountable and contribute its fair share to mitigate all its developmental impact. The question should not be a question of whether Stanford is responsible for one or the other, but how can we make Stanford responsible for the effects of its growth. Therefore, I believe dismissing Alternatives A and B outright due to the impacts stated in the EIR would be a mistake, as we need to find solutions that effectively consider both socio-economic and environmental effects.
While the EIR is an important document whose creation is mandated under the California Environmental Quality Act (CEQA), it is crucial to note its limitations. First, this document is specific to physical environmental impacts. There is no regulatory obligation under CEQA to assess socio-economic concerns. We need to understand these impacts in the totality of the many issues that Stanford's anticipated development creates. Addressing traffic concerns while contributing to a severe housing shortage and forcing workers to commute as much as six hours a day would not take into full consideration the harmful impacts of Stanford's development.
There are many assumptions hidden in the details of the report that a) ignore regional emission effects, b) are calculated using unlikely traffic patterns, and c) presume minimalist mitigation efforts to Stanford's development. A significant oversight revolves around the assumption of vehicle miles travelled (VMT). First, it must be noted that VMT calculations are local statistics, which may make them relevant for local air quality but not for regional emissions. The increase in VMT from the baseline project (as proposed by Stanford) to either housing alternative does not take into consideration the decrease in regional VMT that would necessarily come with moving Stanford affiliates to campus. As Stanford campus is in a job-rich area, not only would VMT from the Stanford affiliates decrease, but likely from the spouses as well. If not provided campus housing, these families, many which are low-income, could live an upwards of three hours away, thereby increasing regional emission.
In addition, the very analyses that underlie the County's estimates of increased VMT, which would then lead to air quality issues, have some serious flaws. Specifically, the VMT analysis assumes that undergraduate students make 1.46 off-campus vehicular trips per day, a seemingly high number considering students, particularly undergraduates, spend the majority of their time on campus. Compared to other universities where students regularly commute off-campus, Stanford is almost entirely self-contained, with accessible markets, dining halls and other facilities. While this does not affect comparisons between Stanford's baseline and the proposed alternatives, the total commutes and VMT in all scenarios are likely exaggerated, meaning that levels of emissions currently deemed "significant" under Bay Area Air Quality Management District (BAAMQD) thresholds may actually not be significant at all.
Clearly, across all these issues, the data sourcing is vague — what is required is clarity about missing data and plans for filling in the gaps, particularly with respect to accurate student and spousal data as well as disaggregated across income.
Additionally, many "conservative assumptions" in the alternative scenarios assume a lack of commitment, by Stanford or otherwise, to traffic mitigation goals. Perhaps, instead of assuming failure, next steps could be to come up with practical solutions to support traffic management. One example is to extend transportation benefits to all workers, since, currently, contracted workers are ineligible for these benefits unless they receive sponsorship. Additionally, Stanford's required commitment to "no-net-new-commutes," which currently only covers one hour in the morning and evening each, could be extended a more realistic rush hour time window (at least two hours). Traffic concerns can be mitigated by Stanford if they are required to invest in better local roads and infrastructure.
Another strategy could be to collaborate across jurisdictions. Many traffic impacts under the alternatives are labelled "significant and unavoidable," as effective mitigations require actions by jurisdictions outside of Santa Clara County. While this may indeed be a hurdle, it is far from insurmountable if made a priority.
I am a graduate student at Stanford, who, while very grateful for the opportunities the university provides, is also deeply concerned about Stanford's impact on the surrounding communities. Luckily, Santa Clara County has several mechanisms to ensure that Stanford is a good neighbor. Two important documents will be negotiated in the upcoming months — the Development Agreement and the Conditions of Approval for Stanford's general-use permit — which will be crucial places for legally binding commitments to impact mitigations, as well as ones unaddressed in the EIR, such as the impact on local schools. Issues of traffic and housing will be pivotal in these negotiations. Let's use this as an opportunity to accurately represent and effectively address all impacts of Stanford development, whether analyzed in the EIR or otherwise, to demand Stanford's accountability.
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