Thank you for the opportunity to comment on the proposed revisions to the University of California Policy on Sustainable Practices. I share the University’s commitment to environmental stewardship. My comments focus not on the aspirations of the policy, but on questions of scope, prioritization, cost, and institutional capacity, issues that I believe warrant fuller consideration before adoption.
I. Resource Allocation and Institutional Focus
As drafted, the policy contains a wide range of prescriptive requirements that appear to require significant staff time, documentation, and reporting. Several provisions raise questions about proportionality and opportunity cost, particularly in light of constrained instructional budgets and long-standing faculty capacity challenges.
For example, the policy contemplates:
• Detailed tracking of “sustainable” procurement categories (including food certifications); I attach an an Excel sheet from our STARS certification that dives into minutiae including how many “certified humane” beef patties Berkeley purchased.
• Auditing of vending-machine product placement, a practice based on “nudge” theory—much of nudge ultimately was not reproducible or had very small effect sizes, making those interventions questionable
• Systematic review of course offerings for sustainability content; again, a situation where staff assembled a 6,000-row Excel sheet instead of supporting teaching and research
• Development of sustainability-focused campus programming and tours; this requirement touts the sustainability program, a weird thing to do on a campus such as Berkeley where other attributes could be celebrated, consider instead a “Nobel Prize Walking Tour”
• Compliance with external certification regimes such as AASHE STARS and LEED at the highest levels.
Each of these initiatives may be defensible in isolation. Collectively, however, they signal “everything bagel” logics and prompt a fundamental governance question: How much institutional capacity should be devoted to documentation and compliance instead of teaching, research, and direct environmental improvements?
II. Administrative Growth and Compliance Burden
Rather than articulating guiding principles, the policy specifies detailed operational requirements, numeric targets, placement rules, certification levels, and timelines. Such micromanagement limits campus flexibility, substitutes bureaucratic judgment for local decision-making, and draws attention away from interventions with greater environmental return.
Across the UC system, faculty headcount has remained largely flat while administrative and professional staffing has grown substantially. Our student-to-faculty ratio is 28 to 1, student to staff is 5 to 1. Berkeley alone hired 1,000 staff in the last two years. Sustainability programs—though well-intentioned—are part of this broader pattern.
Systemwide data indicate that UC now employs dozens of sustainability-focused staff, with total annual compensation exceeding $5 million. The concern is not the existence of sustainability expertise per se, but that highly prescriptive policies inevitably generate:
• New reporting obligations,
• Demand for specialized compliance staff and consultants,
• Increased administrative friction in procurement and operations.
These dynamics are familiar from other compliance regimes. They deserve explicit acknowledgment, particularly when policies are adopted systemwide and without identified funding sources.
III. Absence of Cost–Benefit Analysis
The most significant gap in the policy is the absence of a formal cost–benefit or cost-effectiveness analysis.
The policy articulates ambitious goals—net-zero targets, procurement preferences, food mandates, certification standards, but does not:
• Estimate implementation or ongoing compliance costs,
• Identify funding sources,
• Assess marginal environmental benefit per dollar spent,
• Compare alternative interventions by return on investment.
It is striking that the policy includes a DEI analysis but no deep analysis of financial, operational, or affordability impacts. Sustainability measures that increase the cost of food, housing, or campus services disproportionately affect lower-income students and should be evaluated accordingly, yet the DEI analysis does not contemplate cost transfer to students.
At Berkeley, our campus dining options cost as much as Market Hall (a premium gourmet market). Food is hard to find on the Berkeley campus, it almost uniquely sold by a single vendor who has figured out our procurement system (Yali’s).
Berkeley’s food landscape is a product of procurement complexity, where administrators have told me directly that Yali’s is the only company that “knows how to work with us.”
The administrators who have made it so hard to work with us appear unaware of the costs and pathologies. Given the number of students on campus, there ought to be food trucks and even those mobile hot dog vendors. The food ought to be better, generally speaking, given its cost.
IV. Reporting Proliferation and Administrative Complexity
The policy mandates approximately twenty recurring reports covering energy, water, waste, food procurement, vending machines, laboratory practices, and more.
These reporting requirements are not clearly tied to decision-making authority, budget allocation, or measurable outcomes. The risk is a familiar one: resources diverted toward documenting sustainability rather than achieving it.
Funds used to generate, verify, and transmit spreadsheets could otherwise be invested directly in infrastructure improvements such as energy retrofits, water conservation, or renewable installations.
V. Lack of Prioritization and Strategic Focus
The policy advances mandates across more than a dozen domains simultaneously, without distinguishing between:
• High-impact interventions and symbolic measures,
• Actions with clear payback periods and those with uncertain benefit.
There is no framework for answering a basic question of governance: If resources are limited, which interventions matter most? Without prioritization, campuses face diffuse effort, uneven compliance, and increased administrative strain.
VI. Procurement and Vendor Effects
The policy continues to require that a minimum percentage of procurement scoring be assigned to sustainability-related criteria. In practice, this can favor large vendors with extensive ESG marketing capacity over smaller or regional suppliers who may operate efficiently but lack formal reporting infrastructure. Looking around Berkeley, one sees Sysco and Pepsi trucks instead of the local vendors that service Berkeley restaurants. This very well may be a consequence of sustainability—the companies big enough to afford sustainability programs write reports that our staff read, and thus declare Sysco/Pepsi “sustainable.” I read Sysco’s sustainability literature, which made improbable claims that the fish it caught off the coast of Chile (and presumably flown to California) were sustainable. A local vendor catching fish here in California is probably less impactful on the environment, yet, that local vendor may not be able to afford the staff to create the sustainability talk.
Recommendations
1. Pause implementation until a structured cost benefit analysis is completed, including staffing needs, funding sources, and expected returns.
2. Prioritize high-impact interventions, suspending low-impact or symbolic mandates until their value is demonstrated.
3. Reduce reporting requirements and redirect resources toward direct environmental improvements.
4. Replace prescriptive rules with principles, allowing campuses to select the most effective strategies given local conditions and academic priorities.
Conclusion
The proposed policy reflects laudable aspirations. However, without attention to cost, staffing, prioritization, and institutional capacity, it risks creating a sustainability bureaucracy rather than a sustainable university.