O’Donnell Financial Group
Below is a letter, dated June 24, 2019, from Sustainable TamAlmonte to the Planning Division of the Marin County Community Development Agency regarding Applicant O’Donnell Financial Group’s request for a Master Plan Amendment and Design Review approval to construct a new two-story, 10,887 sq. ft. hotel/ apartment complex, consisting of 11 extended-stay hotel suites and 10 rental apartments for a total of 21 residential housing units, at 150 Shoreline Highway, Mill Valley, CA 94941 (Manzanita Area).
A Master Plan Amendment is required because the project site is in a Master Plan area. Design Review approval is required because the project is located in a Planned District.
Click HERE to view the plans of the proposed complex.
PLEASE ATTEND the upcoming Tamalpais Design Review Board meeting on July 3rd, when the board will discuss the proposed hotel/apartment complex:
WHAT: Tamalpais Design Review Board Meeting
WHEN: July 3, 2019 at 7 PM
WHERE: TCSD Cabin, 60 Tennessee Valley Road, Mill Valley
June 24, 2019
Dear Planning Division of the Marin County Community Development Agency,
We wish to make the following comments and recommendations regarding the proposed hotel/ apartment complex at 150 Shoreline Hwy in Mill Valley.
I. CIRCUMSTANCES HAVE DETERIORATED SIGNIFICANTLY AT 150 SHORELINE HWY
Situated on approximately 100 feet of fill, 150 Shoreline Hwy is an extremely hazardous site, subject to: Severe flooding (within the 100 year flood plain); Sea level rise; High traffic congestion (LOS “F”), High air pollution; High seismic activity; Subsidence; and Mud displacement. It is also located in proximity to vulnerable natural habitat and endangered species.
Conditions at the site have deteriorated significantly since the adoption of the 1992 Tamalpais Area Community Plan, the adoption of the 2007 Countywide Plan, and since the Board of Supervisors approved the Project Initial Study and Negative Declaration for the proposed deli and residential project in May 2011.
Since 2011, traffic congestion along Shoreline Hwy has significantly increased, flooding has become more frequent, and sea level rise is now predicted to rise sooner and higher than previously forecasted. Please see the maps of sea level rise in Addendum IV - Maps of Sea Level Rise of this letter.
Due to the increase in traffic, we suspect that the air quality has further degraded also. Please see the attached comments by Air Quality Expert Geoffrey Hornek's on the DRAFT 2012 Marin County Housing Element SEIR. Mr. Hornek's comments include an analysis of the air quality at 150 Shoreline Hwy. He states that future residents at the site would be subject to potential significant cancer risk from Toxic Air Contaminant (TAC) emissions.
II. DO NOT APPROVE A MASTER PLAN AMENDMENT & DESIGN REVIEW FOR CONSTRUCTION OF A NEW HOTEL/APARTMENT COMPLEX, CONSISTING OF 21 RESIDENTIAL HOUSING UNITS, AT 150 SHORELINE HWY BECAUSE SUCH HOUSING IS NOT APPROPRIATE AT THE SITE
The applicant proposes to construct a hotel/ apartment complex, consisting of 11 extended-stay hotel suites and 10 rental apartments for a total of 21 residential housing units, at 150 Shoreline Hwy.
The land use at 150 Shoreline Hwy is Multiple Residential – Visitor Commercial and this use allows for development of multiple-family housing. However, due to the extremely hazardous conditions at the site that present serious issues involving residents’ health and safety from environmental impacts, this use is no longer appropriate and should be prohibited.
III. REQUIRE A FULL CALIFORNIA ENVIRONMENTAL QUALITY ACT (CEQA) REVIEW OF ANY DEVELOPMENT PROPOSED AT 150 SHORELINE HWY
150 Shoreline Hwy sits within the Baylands Corridor of the Marin Countywide Plan and is thereby governed by regulations pertaining to this protective designation. Please see Addendum II - Excerpts from the Marin Countywide Plan regarding the Baylands Corridor.
On Page 2.4-35, BIO-5.4 “Limit Development and Access”, the Countywide Plan states; “Require an environmental assessment where development is proposed within the Baylands Corridor”.
Due to the above requirement for parcels located in the Baylands Corridor and the numerous environmental constraints that impact 150 Shoreline Hwy, any proposed development at the site should require a full California Environmental Quality Act (CEQA) review, including a review of cumulative environmental impacts.
As mentioned before, 150 Shoreline Hwy sits within the Baylands Corridor of the Marin Countywide Plan and is thereby governed by regulations pertaining to the Baylands Corridor. Please see Addendum II - Excerpts from the Marin Countywide Plan regarding the Baylands Corridor.
The Marin Countywide Plan encourages the following to happen within the Baylands Corridor:
- Limit development and development impacts;
- Preserve and enhance the Baylands ecosystem;
- Encourage acquisition of Baylands for open space;
- Restore marshlands; and
- Protect Movement Corridors.
According to the CWP, the preferred use of 150 Shoreline Hwy would be acquisition for open space and restoration of the property back to marshland. Besides other benefits, this would help to lessen flooding in the area.
In the future, as sea level rises higher, the adjacent properties on the East Side of Shoreline Hwy may also be acquired for open space and marsh restoration. Together the sites could allow for the retreat of baylands / wetlands habitat and wildlife as waters rise.
There are numerous concerns about adding more development on a floodplain that is already flooding and compromised during the year. Additional runoff will exacerbate the problem and bioswales are inappropriate on marshland. The flooding has and will continue to increase as evidenced by all mapping of present and future sea level rise. The proposed grading and impermeable paving will only exacerbate the problems.
The proximity to water inlet, the historic marsh and 100’ deep bay mud and subsidence and mud displacement make future development in this area inappropriate. The elevated building may rise in the future but the access to it won’t and the public should not have to become responsible for the expense of protecting and sustaining access to this privately-owned building. To allow further development in this area is shortsighted and not cost effective.
We urge the County to seek funding from appropriate sources to purchase the property for open space and to restore it back to marshland.
If 150 Shoreline Hwy is not purchased for open space and marsh restoration at this time, then development at the site should be limited to the greatest degree possible.
A. Sections of the Marin Countywide Plan (CWP) pertaining to the Baylands Corridor encourage limited development at 150 Shoreline Hwy:
Per the enclosed excerpts of the Marin Countywide Plan that relate to the Baylands Corridor (Please see Addendum II of this letter), development should be limited within this protective designation.
B. Following the guidelines of the Tamalpais Area Community Plan will result in a smaller building size:
In Addendum I of this letter, we list relevant excerpts from the Tamalpais Area Community Plan, regarding compatibility with the neighborhood, maximization of views, perimeter landscaping, height, etc. In order to follow these requirements, the proposed building size would need to be reduced.
- Clarification of the 25’ height limit for development on the East side of Shoreline Hwy in Manzanita, which is required by the Tamalpais Area Community Plan: The flood risks would result in elevating the proposed building above 25’ in violation of the Tam Plan.At the time that this height was established the authors intended this to be the limit on this side of Shoreline Highway (any other reference is an error as corrected by the Tamalpais Area Community Plan Updates in 2013). In 1992 there was no provision for the FEMA expectation of an increased 3’ elevation for flood protection. Therefore, the intended height should be adjusted to incorporate this new mitigation rather than effectively increasing the building height limit from visual ground level.
C. Restrict development to the lowest end of the applicable FAR where LOS standards will be exceeded:
Per the below excerpts from the Built Environment – Transportation Section of the Marin Countywide Plan, “New development should be restricted to the lowest end of the applicable residential density/ commercial Floor Area Ratio (FAR) range where Level of Service (LOS) standards will be exceeded at any intersection or road segment or worsened on any grandfathered segment.”
Due to the extremely hazardous traffic congestion in the area, a rigorous traffic study should be conducted to evaluate traffic conditions at the site as well as cumulative traffic impacts from other proposed developments in the area and the expected rise in visitation to the National Parks. If the LOS standards are worsened, then the proposed office building should be restricted to the lowest end of the applicable FAR.
Relevant Excerpts from the Built Environment – Transportation Section of the Countywide Plan (See Addendum III of this letter)
- Pg. 3.9-13, BUILT ENVIRONMENT, TRANSPORTATION - TR-1.e Uphold Vehicle Level of Service Standards:“ Uphold peak-hour vehicle Level of Service standard LOS D or better for urban and suburban arterials and LOS E or better for freeways and rural expressways.
New development shall be restricted to the lowest end of the applicable residential density/commercial floor area ratio range where the LOS standards will be exceeded at any intersection or road segment or worsened on any grandfathered segment.”
- Page 3.9-18 BUILT ENVIRONMENT, TRANSPORTATION - TR-1.r Reduce Congestion on Grandfathered Road Segments: “Encourage the Transportation Authority of Marin or other responsible agency to prepare plans to reduce congestion on grandfathered road segments that do not meet current LOS standards. These plans should rely on programs and policies other than physical infrastructure improvements to the extent feasible.”
VI. DEVELOPMENT AT 150 SHORELINE HWY SHOULD BE CONSISTENT WITH THE TAMALPAIS AREA COMMUNITY PLAN – EXCEPT FOR THE ALLOWANCE OF HOUSING
Except for the allowance of housing (discussed above), development at 150 Shoreline Hwy should be consistent with the goals, objectives, policies and programs specified in the Tamalpais Area Community Plan (TACP), which are listed in Addendum I of this letter.
VII. INSUFFICIENT PARKING
If against our recommendation, you allow a hotel/apartment complex to be built at 150 Shoreline Hwy, then require sufficient parking. The proposed plan only provides 20 parking spaces. This is insufficient for 21 residences (11 studios and 10 apartments) and visitors regardless of the fact that the building is located near the Manzanita bus stop.
It may be presumed that the proposed complex would need less parking because inhabitants would rely on public transportation instead of vehicles for their transportation needs. However, this is a false presumption in Marin.
Due to Marin’s insufficient and inconvenient public transportation and the need to carry children, equipment or large purchases, the vast majority of Marin residents rely on their personal vehicles to reach their destinations. Infrequent bus service provides transportation primarily in the North/South direction.
There is little public transportation available for West/East travel. Many members of Marin’s population cannot walk or bike very far (E.g. Marin’s growing elderly population) or else find these non-motorized forms of transportation to be inappropriate for where they are going (E.g. They need to transport children or carry heavy objects). Therefore, most Marin residents rely primarily on their personal vehicles for transportation and will need places to park these vehicles.
Insufficient parking spaces do not stop residents from driving. It simply forces residents and guests to park their vehicles in public parking lots, which are needed for other purposes, or park on streets.
There should be a minimum of one parking space per studio and one parking space per one-bedroom apartment plus additional parking for visitors. If an apartment has two bedrooms, then two parking spaces should be provided for the apartment.
If all the proposed apartments are one-bedroom, and therefore the proposed complex would consist of 11 studios and 10 one-bedroom apartments, then we recommend a minimum of 21 parking spaces for the tenants plus 4 visitor parking spaces.
The environmental constraints that impact 150 Shoreline Hwy mandate a very cautious approach to consideration of any development at the site. We urge you to follow our above recommendations, which include:
- Do not approve the Master Plan Amendment and Design Review for construction of a new hotel/apartment complex, consisting of 11 extended-stay hotel suites and 10 rental apartments for a total of 21 residential housing units, at 150 Shoreline Hwy;
- Require the applicant to follow the Baylands Corridor and Tamalpais Area Community Plan guidelines in all respects, except for those sections that allow housing in the hazardous commercial areas;
- In accordance with the sections of the Countywide Plan that relate to the Baylands Corridor, seek funding from appropriate sources to purchase 150 Shoreline Hwy for open space and restore it back to marshland. If acquired and restored, the sites on the East Side of Shoreline Hwy could help lessen flooding and allow for the retreat of baylands/wetlands habitat and wildlife as waters rise;
- Limit new development at 150 Shoreline Hwy to the greatest degree possible if acquisition of the site for open space and marsh restoration is not possible at this time;
- Require a full CEQA review of any development proposed at 150 Shoreline Hwy., including a review of cumulative environmental impacts, based on the requirements for parcels located in the Baylands Corridor and the numerous increasing environmental constraints that impact the site; and
- If against our recommendation, you allow a hotel/apartment complex to be built, then require sufficient parking. At minimum provide one parking space per studio and one parking space per one-bedroom apartment plus additional parking for visitors.If an apartment has two bedrooms, then two parking spaces should be provided for the apartment.
Thank you for your conscientious consideration.
Very truly yours, Sharon Rushton, Chair, Sustainable TamAlmonte
Cc: Supervisor Kate Sears
Cc: Director Brian Crawford