March 20, 2025
San José City Council
200 East Santa Clara St
San José, CA 95113
RE: San José City Council March 21 Agenda Item 6.1: San José Municipal Electrical Utility Exploration
Dear Mayor Mahan and San José City Councilmembers,
The Sierra Club Loma Prieta Chapter, Santa Clara Valley Bird Alliance, Mothers Out Front Silicon Valley, and the San José Youth Climate Action Team are opposed to the development of the 159 acres of open space south of the Regional Wastewater Facility and North of Highway 237. San José should instead explore the conversion and repurposing of existing development if it chooses to incentivize the construction of data centers in this area. We are also concerned with the potential for data centers to use gas-powered fuel cells, which generate a disproportionately large amount of greenhouse gas emissions compared with other energy sources.
This site is home to numerous protected species (including burrowing owls, and a nesting pair of golden eagles). It contains grasslands, wetlands and vernal pools, and has immense potential for ecological restoration and habitat creation. In addition, open space near the Bay may prove critically important as San José adapts to climate change, flooding of Coyote Creek and the Guadalupe River, and sea level rise. Protecting these buffer lands aligns with environmental sustainability and biodiversity conservation goals.
The 159 acres of open space, designated in the Plant Master Plan as “buffer lands”, were marked for development in the 2013 Plant Master Plan1. The City of San José Council Policy 6-312 directs the use of these lands, and includes,
“Policy 6-31, 2. Buffer Land uses must support NPDES permit compliance and not constrain the Plant's flexibility to respond to unknown future requirements. Additional need for treatment or expansion takes precedence over any other potential uses. Land uses should provide flexibility for Plant and Recycled water system expansion beyond the defined expansion area to accommodate future unknown requirements. Therefore, land uses that are unrelated to Plant or Water Recycling Facilities operations, that propose permanent buildings or hardscape should be discouraged. Sale of buffer lands is strongly discouraged in favor of leasing. Land uses should maximize use of recycled water and/or minimize flows to the Plant. Land uses that reduce mass loading of pollutants to the Bay are preferred. This may include land use options that contribute to protecting the water quality of the South Bay, and could potentially be used for pollutant offsets.”
Developing on buffer lands may constrain the City’s ability to adapt to climate uncertainties, including flooding and sea level rise. These lands are vulnerable to rising groundwater and associated liquefaction risks. The loss of these open spaces and creating increased impermeable areas will have long-term environmental consequences that reduce resilience to flooding and sea level rise, and greatly diminish opportunities to employ nature-best solutions to protect infrastructure and communities.
“Policy 6-31, 3. Buffer Land uses must protect existing biological resources. Existing biological resources include areas with wetlands characteristics, grasslands with burrowing owl habitat, and the Coyote Creek Riparian Corridor. Land uses should not adversely impact state or federally protected species or the habitat that supports them, and ensure habitat diversity. Any landscaping on buffer lands should favor use of native plants and support the Riparian Corridor Policy.”
The buffer lands are critically important to the persistence of burrowing owls and other special status species in the region. These lands provide hunting grounds for raptors, and migration and roosting sites for a large number of migratory bird species.
“Policy 6-31, 4. Buffer Land uses should provide environmental benefit. Buffer Land uses that provide direct benefit to habitats that support species of special concern should be given priority. Land uses should be considered that provide overall environmental benefits and regulatory credit. Land uses that do not provide environmental enhancements must be compatible with existing or created habitat on-site and minimize any environmental impacts.”
Data centers provide no environmental benefit. Instead, they consume vast amounts of electricity, potentially tripling the City’s demand for electricity, according to the staff report. This could strain San José Clean Energy’s ability to meet the demands of its residents as San José continues to electrify in pursuit of its Carbon Neutrality by 2030 Goal. Data centers also require significant water resources for cooling, which can strain local water supplies, especially in drought-prone regions. Additionally, their construction and operation adjacent to sensitive burrowing owl habitat could lead to habitat destruction, increased urban heat island effects, and electronic waste generation.
Please do not incentivise the development of the 159 acres of open space as part of any agreements with PG&E or as part of any plans for San José Power. The City should abide by its policies, and at this time, re-consider the 2013 designation of “economic development lands.” San José should instead analyze and prioritize the value of this open space for habitat, and not data centers. Should the City pursue the incentivization of data centers, it should first pursue the conversion and repurposing of existing development in the area. Finally, as the City negotiates its agreements, please ensure that gas-powered fuel cells are not used to power data centers.
Sincerely,
James Eggers
Senior Chapter Director
Sierra Club Loma Prieta Chapter
Matthew Dodder
Executive Director
Santa Clara Valley Bird Alliance
Daphne Zhu
Co-Lead
San Jose Youth Climate Action Team
Linda Hutchins-Knowles
Co-founder and Team Coordinator
Mothers Out Front Silicon Valley
1 https://www.sanjoseca.gov/home/showpublisheddocument/206/636611441889800000
2 http://sanjoseca.gov/home/showpublisheddocument/12821/636669915148100000