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Comments on the proposal to renovate the Mill Valley Lumber property

The following letter has been submitted to the Mill Valley Planning Commission, commenting on the proposal to re-purpose and rehabilitate the former Mill Valley Lumber property.


March 24, 2016

Ms. Anne Bolen, Chair and Members of the Planning Commission.

City of Mill Valley

Mill Valley, CA 94941

Re: Mill Valley Lumber Yard Project

Dear Chair Bolen and Planning Commissioners,

I have had the opportunity to review the proposal for the Mill Valley Lumber Yard site and have the following concerns.

1) Traffic and Parking:

I will let others elaborate on the technicalities of this, but this proposal is close to tripling the current commercial area from about 6,000sf to over 17,000sf. (I should add that most of the current area being used as retail: Guideboat is primarily an online retail outfit and this store, according to the Owner, was never envisioned as a major shopping draw. If the tenant changed, one could reasonably expect much more site traffic and parking.) I should also add that the current 6,000sf of retail is more than the amount of retail that existed when the site was a lumber yard.

The proposal also suggests that there is not a major change in use of the site since the storage sheds (Miller and Planer) were actually “retail”, when the site operated as a lumber yard. This is not true, and storage vs commercial under the building codes are treated very differently. The amount of work needed to bring the storage sheds up to commercial uses illustrates this. I also submit that the number of employees would at least triple with this proposal. Where are they parking?

The proposal states that there were no parking spaces on this site when it operated as a lumber yard. I remember parking there (there was space for at least 3 cars). The proposal also omits the fact that there was another lumber yard site on the other side of Miller that was used for parking (mostly employee) and storage. This site now has 3 houses on it and has, thereby, increased the residential nature of the “Passage”.

The proposal suggests that the City will be adding parking along the Presidio Avenue frontage. This is true as part of the Miller Avenue Streetscape plan. However, this parking was considered as a community and neighborhood resource and not as an overflow parking area for a for-profit commercial use across the street.

I can envision some tenants and shoppers biking and walking to the site during the day during good weather, but not at night, to go to dinner. Furthermore, we all know that currently the majority of Mill Valley residents use their cars, especially those who live in the hills and cannot be expected to carry their purchases home on a bicycle.

Finally, parking in the residential neighborhoods is becoming increasingly more difficult given the fact that no one seems to use their driveways nor garages for parking any more, which is in conflict with the zoning ordinance and remains unregulated by the City.

I believe that under current zoning over 80 parking spaces would be required for this site. Even given the suggested shared parking arrangement, this does not work.

2) Restaurant use:

This is a residential neighborhood. Adding a venue with alcohol that stays open late (10:30-11:00pm) on essentially a traffic island is not only unsafe but a major, major change in use for the surrounding neighborhood on both sides of Miller: increased noise, food odors, traffic and parking. A 1500sf restaurant needs way more than the provided spaces for employees + customers, even considering a shared parking scenario. I can also attest to the fact that we go to dinner downtown most Friday nights, and we drive and park; I have rarely seen a resident dressed for dinner on a bicycle. This is totally unrealistic.

I also am surprised that the City would allow waste lines and grease traps, etc. OVER the creek. There was never a restaurant in the Planer building before, so this risk did not exist. I don’t think a residence could do that?

I can see a cafe open for breakfast and lunch, which closes around 4 or 5pm (similar to the Shoreline Coffee Shop), essentially before the end of the day commute.

I believe there is also a suggestion for live outdoor music or a beer garden type venue. Any of us who have been in City Hall on a warm evening when the Sweetwater has its doors open and/or talked to the neighbors at Beerworks knows the noise levels and, in the case of Beerworks, the lack of enforcement, which accompanies these uses. Remember, this is NOT the real downtown Mill valley which centers on Lytton Square, it is a neighborhood. I could see a few events on weekend nights with a permit and neighborhood notification.

Outdoor dining of any sort after hours should not be allowed.

I think the idea of artist spaces is a great one.

4) The use of a PD:

This is what the zoning ordinance says:

20.57.010 Combining district—Creation.

There is created a combining district to be known as PD planned development district, which may be combined with any of the basic zoning districts designated in this title and applied to any individual property.

The purpose of the PD district is to provide the City with a tool to review, guide and promote the orderly and beneficial development of those areas which may be of particular impact, value and benefit to the entire community.

The addition of a PD district designation to any basic zoning district shall not operate to reduce or eliminate any requirements established by the basic district regulations or other requirements contained in this title applicable to any district to which the PD district is added unless expressly provided herein; provided, however, that if any of the regulations specified in this chapter for a PD district conflict with the basic district regulations, then the regulations for the PD district shall apply. (Ord. 787 § 2, February 20, 1973)

As I read this, this is not a blank check to do whatever you want nor has it been interpreted that way in the past. (Redwood Lodge is a good example.) This project is non-compliant in height and parking for starters there may be other conflicts as well with the proposed change of use.

5) Historic Preservation:

I am not a historic architect, per se, but I do work on many historic/heritage homes in Mill Valley and the Bay Area. I work in conjunction with an HRE prepared by a qualified consultant and I have also worked with Mark Hulbert, the consultant on this project. I do not believe that Mark got it right this time. I also am very familiar with the Secretary of Interior Standards. (SIS) I am consistently advised not to change too much the “public” facades of the architecture.

The beauty and historic essence of the Miller and Planer Buildings are their color, their long unbroken windowless facades, and the uneven nature of the triple lap siding. They are very authentic looking in all respects, as well as well-proportioned. The end facades with the MVLY signage are iconic.

I submit that this proposal radically changes the feel of these public facades, with the proposed windows and by raising the heights, (which I believe exceed the height limit from close to 25’ to close to 29’). In addition, for the Miller Building, these windows are on the property line! It is not even clear where this proposed window style came from?

I take no issue with the visuals of the renovation and enclosure of the interior facades of these buildings.

The troubling part of all of this is that these windows visible from Miller are really not necessary for the suggested use, but are there to accommodate the very aggressive commercial program for this site (2 story retail at the Miller and Planer Buildings - so height needs to be increased.) The tenant spaces, which are a bit deeper than a residential garage space, can easily be used without all those additional windows on the exterior. The set back clerestories proposed on the Planer Building seem more in keeping with the facades, and perhaps an interior clerestory at the Miller Building would work? The windows on the end walls totally destroy the iconic nature of the facades. I realize that the restaurant is trying to capture Mt. Tam views, but that is not a license to add windows to this façade.

I hope that the PC will carefully scrutinize all the details: suggested lighting, “ye olde” graphics, etc. and determine whether they truly support preservation and enhancement of the buildings’ iconic historic character.

I STRONGLY and URGENTLY recommend that a peer review for the historic report be required by the Commission. This site is too fragile and too important. We need to get this right. To be clear, the support letter from the MVHS does not include the now-defunct preservation arm of the society and therefore is not a legitimate resource for historic preservation evaluation.

I should also add that there has not been a great track record by the Owners/City so far on this site. The response comments to the PC and neighborhood concerns in the Initial Study are dismissive and combative as opposed to being carefully considered and sensitive to the neighborhood’s concerns.

Our former and discredited Planning Director allowed The Guideboat renovation without PC review and under a repair and maintenance permit. As a result, it resembles a speculative strip mall; there is nothing genuine about it. This building needs to be added to the HRE as it does not fit into the historic character and never underwent proper review. Since it is now covered under the newly created historic district umbrella, it is right that the HRE looks at this.

The parking spaces along Miller were added within a creek setback without a building permit (as I understand it), as was the moving of the container buildings closer to the creek now housing retail uses. (There is also dubious ADA bathroom access for these spaces.) Most architects currently working with the City are very aware of the exhaustive review with CMP’s, etc. that are required for even minor renovations in the City, and this site should be no different. One could argue that it requires MORE given the safety issues involved. These owners appear to have received less scrutiny than a normal project, and I question why that is.

In closing, I would like to add that there has been a huge public relations effort in conjunction with this proposal. I am sure many well meaning residents, who do not live near by, (I do note that one letter in support is from an architect who works but does not LIVE nearby) and have not scrutinized the design and other details of this proposal, believe that the concept of artist spaces and a beer garden/restaurant would be great. However, letters do not constitute an entitlement, and I would hope that the PC approaches this very cautiously and asks for clarification on traffic, parking, noise and safety impacts as well as require peer review for the historic report. Let’s look beyond the smoke and mirrors and see this aggressive proposal for what it is.

I ask that the PC do the following:

1) Provide clear direction on allowable uses and require a CUP for the entire site. Provide direction on the maximum amount of commercial space.

2) Require real solutions to the parking problem, including reduction of commercial space.

3) Require an acceptable preservation program for the entire site with peer review that looks at alternative solutions, (such as no windows on Miller and not raising the buildings.)

Respectfully submitted,

Heidi Richardson, Architect

Former Planning Commissioner and two term Chair of the PC