My comment on the Central SOMA EIR
Back in February, I wrote a comment on the Central SOMA plan Environmental Impact Report. Here it is, word for word, with a short postscript. Enjoy.
I read much of the EIR, and I generally like what’s going on, though as you probably guessed, I wouldn’t have bothered writing a comment if there weren’t a “but”.
Just as background here, my concern here is with the housing shortage. Lots of people want to live in the Bay Area, either because they’re from around here, or because it’s an economically successful and well diversified region with lots of interesting and lucrative jobs, or because of the region’s cultural dynamism, or the comparatively inclusive attitude toward those whose ethnicity, sexual orientation, &c are considered too eccentric elsewhere. But amid all that acceptance and tolerance, there’s one thing we don’t do, and that’s actually build housing for all the people that want to live here, and I think that’s a shame. The plan would add a lot of potential housing, and that’s good.
The draft EIR has nearly 1000 pages of documentation on how all of this upzoning is not some sort of environmental disaster in the myriad ways that California considers things to be potential environmental disasters, including such apparent catastrophes as shadows on existing condos. You convinced me. It’s not an environmental disaster.
In fact, quite the opposite. Dense mixed use neighborhoods have much less environmental impact than people commuting in from Tracy or Stockton or Gilroy, which is realistically what you get only even more of when you change nothing. And that’s where I’m ambivalent about the EIR as an EIR.
What bugs me about the report is the alternatives analysis. Sure, the document demonstrates that the higher density alternative is not appreciably worse than building nothing, or than building less. But how does it compare to building more? Especially given the switch from Level of Service to Vehicle Miles Traveled, it seems that isn’t necessarily a foregone conclusion. Shouldn’t we be considering the possibility that a higher density alternative has less environmental impact?
After all, with less housing in SOMA, we have more people driving cars in from elsewhere. If for a minute we set away the details of point-by-point impact review, I think that allowing more urban housing has less environmental impact. Not just less than some other plan for regulatory change, but also less than the zero-build alternative. Because zero-build doesn’t mean zero-change. Business may have its ups and downs, but the structural economic advantages of prime metro areas like ours aren’t going away. The region will continue to attract a lot of people. The default is not that everything stays as it is now. The default is that people move further and further away from the jobs centers until they find a place they can afford. When it comes to professionals like me, zoning restrictions may just be a way to transfer money from our wallets to that of the landowners, but there many people who work here whose wallets aren’t big enough for that. I’ve spoken to people who commute from as far as Sacramento!
I think there are good arguments to be made that the housing shortage is not just a socioeconomic problem, but also an environmental problem. The alternative to more housing in San Francisco is more sprawl elsewhere. Even if we don’t consider the incentive we create for additional sprawl to be pushed for elsewhere, densification can happen regardless, simple because more people pack into a housing unit, and that can definitely happen in Stockton just as well as it can happen in San Francisco. And having lots and lots of people commute in from elsewhere has all sorts of impacts on Vehicle Miles Traveled and climate change.
Or, if you aren’t allowed to consider the effects of things that happen elsewhere, since environmental damage that we can help avoid elsewhere is harder to incorporate into this type of analysis than damage caused directly by the changes, then think of it as additional mitigation. The plans have some impact on Vehicle Miles Traveled and on climate change. Having more density means less traffic, and also people living in an urban environment that is generally less impactful to the environment in numerous ways than living in lower density areas. This is not a potential future thing. It’s something that’s already happening. And adding more housing, including in the blocks that are weirdly set aside for PDR, helps mitigate the environmental impact of the project. Better than any of the alternatives under consideration.
Since writing this, I’ve heard a lot of arguments about how the Central SOMA plan is likely to lead to a lot more office space and less residential development than I thought at the time. I still don’t think it’s worse than nothing, though it may be a close call. But I think it also reinforces the point I made back in February, so I figured I’d dig this up and post it.
