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An interesting development occurred over the past few days and virtually under the radar of much of the media in the Bay Area. Two environmental impacts reports were released at almost the same time: one for the Candlestick Point / San Francisco 49ers Stadium development and the other for the SF Niners stadium proposed for Santa Clara.

I also must explain that I'm biased toward the idea of keeping the 49ers in San Francisco, but I'm not beyond telling it like it is with respect to how the enviromental impact reports are presented.

I've read both EIRs (it was part of my role as Economic Advisor to The Mayor of Oakland when Elihu Harris was Mayor and for Robert Bobb before I worked to try to bring the 2005 Super Bowl to Oakland) and while at 3,000 pages (I didn't read all of the pages), the Candlestick Point includes comments and a detailed and well-organized list of anticipated impacts and ways to work to dampen or eliminate them (called "mitagations"), the Santa Clara DEIR is not so well-written.

I've got to say the Santa Clara EIR's not very good at all. In fact, some of the responses to comments are irresponsible and don't show that the project's impacts are being well considered.

Many of the Santa Clara EIR answers to comments are defensive rather than technical and call into question to what degree this document was rushed into production to beat the City of San Francisco's Candlestick effort.

There's a threat of comments regarding the anticipated transit use that would be generated from a new stadium in Santa Clara. The problem with the Santa Clara DEIR is that it bases future estimates of use of cars, buses, and trains on the existing Candlestick Park stadium, which the Candlestick Point DEIR seeks to replace with a new stadium.

In other words, the use of trains versus cars is dependent on the design of the streets, roads, and buildings with respect to each other. The Santa Clara DEIR does not seem to reflect that.

Take this comment / response example:

Comment B-2: Table 15 indicates tbe modal split at the existing stadium is: 82% auto, 10% charter bus, and 8% transit for attendees; 90% auto and 10% transit for employees. For the proposed stadium, modal split is 74% auto, 7% cbarter bus and 19% transit for attendees; 80% auto and 20% transit for employees. Since Candlestick Park is situated within a rich public transportation network, it should have higher charter bus and transit modal splits compared to the proposed stadium. On the contrary, the proposed stadium shows higher charter bus and transit modal splits. What are the underlying assumptions to justify these modal splits tor the proposed 4gers Santa Clara Stadium?

Response B-2: While the City of San Francisco overall has a good public transportation network, the area where Candlestick Park is located does not. There is no rail transit of any kind available to Candlestick Park attendees. The only transit currently used is chatter and municipal buses. As explained in the EIR (pages 176-178), an extensive multi-modal transit system serves north Santa Clara. The assumptions for each type of available transit are described on pages 177-178, including subsections labeled "Bus and Light Rail" and "Heavy
Rail Service".

The Santa Clara DEIR states:

There is no rail transit of any kind available to Candlestick Park attendees.

Hmm....

If that's the case, why is it I can take either BART, Caltrain, or Muni Metro rail and step on the Candlestick Express bus? Yes, it's not direct to the stadium's front door, but its rail and its not far away. Moreover, an EIR is a technical report that's supposed to be devoid of such errors in wording. It's the one place where detailed, accurate description is expected and vital to the success of the project.

The Santa Clara EIR was written as if by a snickering, snipping bureaucrat who had no patience with questions from, well, other bureaucrats from Bay Area agencies, which are in abundance in the document.

By contrast, the Candlestick Point DEIR, while it does concern a much larger 700-acre development, does in detail explain transit impacts and professionally lists the answers to anticipated impacts. There's not the hint of schoolmarm whining that dominates the comment responses in the Santa Clara document.

All of this should make former San Francisco 49ers President Carmen Policy more excited over the prospects for the successful construction of a new 49ers Stadium at Candlestick Point in San Francisco.

But regarding Santa Clara, the San Francisco 49ers should be ashamed of themselves for allowing such a substandard EIR to be produced. I've seen a lot of EIRs in my time and this one's just plain terrible.

If this is an example of what we're to expect, 49ers owner John York should jettison his Santa Clara stadium efforts and work with the more professional team over the Candlestick Point development. Yeah, I'm biased, but it's not without justification.