City Council members: I believe that it is premature to conduct an EIR for the ESC. I have taken this position when this same issue has come up before you twice in 2004, and I believe that the arguments that an EIR is premature are even stronger due to recent developments. Many of the issues to be addressed by an EIR are secondary and subsidiary to the choices that have not yet been made and hence risk being irrelevant. Unnecessary front-loading of expenses on a potential project are a too common management mistake: You can find that you have painted yourself into a corner. Alternatives that would otherwise have been dismissed are kept alive because it is psychologically and politically too difficult to write-off the money spent on those alternatives. And when you do have the courage to make such write-offs, that often creates obstacles to spending the money needed to advance practical alternatives. "Damned if you do. Damned if you don't." The widespread assessment is that the technology to be used in a potential ESC is in a period of rapid change. This means that the economics of the current alternatives are likely to change substantially as they mature, and that some of the current alternatives will be superseded. The "bleeding edge" nature of the ESC proposal was highlighted in a previous hearing when a Council member (I believe it was Ojakian) asked about the basis for the cost figures and was told that staff did not have a comparable facility to use in making those computations. Since Palo Alto is not in a position of having to an immediate choice, it seems wise to take a more disciplined and incremental approach to the decisions on the potential ESC. -- Douglas B. Moran 790 Matadero Avenue Palo Alto, CA 94306