The Marin Post

The Voice of the Community

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John Palmer

Scott Valley HOA comments on the Richardson Terrace project proposal

The following letter by the president of the Scott Valley Homeowners Association has been sent to the Mill Valley Planning Commission to comment on the upcoming hearing on November 17, 2022 on the proposed Richardson Terrace mixed-use development at 575 E. Blithedale Avenue.


Dear City Manager, Planning Director, and Members of the Planning Commission,

I am a 52-year resident of Mill Valley, and for 28 of those years, I have lived in Scott Valley, where traffic on Blithedale is a fact of daily life. I am currently the President of the Scott Valley HOA, with almost 200 homes in our constituency, and am writing this letter in that capacity with the unanimous support of its Board.

I was very active in the last iteration of Friends of Kite Hill, an ad-hoc alliance of 9 of the HOAs and neighborhood associations in the immediate vicinity of Richardson Terrace. This is the first of two letters I am sending regarding that project, this one specifically to refute some of the findings in the traffic report from WTrans.

Friends of Kite Hill, under my direction, commissioned a traffic report in 2012 from Pang Ho, who does traffic studies for many Bay Area cities (See attachment, below). When the current proposal for Richardson Terrace was set for a hearing, I re-contacted Mr. Ho, and commissioned an update (attached here), again for the benefit of our alliance, and for the benefit of the Planning Commission and anyone who may doubt, as I do, the conclusions of the WTrans Report. In addition to his report, I have attached his CV and other credentials.

Just for starters, the WTrans report based all of its findings and conclusions on traffic counts that were done in 2021, while many COVID restrictions were still in place. Obviously, with schools now in full session, youth sports activities in full swing, stores re-opened, and people returning to work in offices at least a good part of the time, there’s a lot more traffic in late 2022 than in 2021.

This fact alone should disqualify the WTrans report because as noted, all of its conclusions were based on objectively outdated data.

The comments by Dalene Whitlock of WTrans, dated 11/4, in the recently posted Staff Report addressing this issue, as raised in the letter from Mr. Kennedy, are defensive, not at all instructive, and simply ignore the obvious – that there is a lot more traffic today than a year ago. She states:

“The traffic data used for the study was obtained during a time that would reflect typical current traffic volumes. Regardless of what factors have changed traffic patterns over time, using counts obtained on a typical day is a standard approach to traffic analyses.”

In other words, her response to basing conclusions on objectively outdated information is simply to pronounce, without evidence, that traffic today is basically the same as it was a year ago when many COVID restrictions were still in place, or if it isn’t, that such increases don’t matter, even though the report’s conclusions were derived from them; she then concludes that the WTrans method, relying on outdated data and then defending its use, reflects a “standard approach.”

This response reflects faulty logic, to put it mildly. A new traffic count is needed, and all conclusions derived from the old counts should be re-examined.

I have excerpted some of the findings from Pang Ho’s report for your convenience. Numbers 1-8 below are direct quotes from Mr. Ho’s letter, then my comments resume.

In reading the WTrans report and studying the site plan, I note there is no turnaround inside the property itself. This is extremely problematic for delivery and emergency vehicles in particular. Frankly, I don’t understand how the MV Fire Dept. signed off on this plan, and I don’t understand how large trucks are going to get out of the property once it’s filled with cars, people, bikes, and other delivery vehicles. Will they have to back out onto Blithedale?

How will that work, in practice?

At the very least, the Richardson proposal should be continued while all these deficiencies are fully re-considered, and until a new, accurate traffic count can be completed. Ideally, the project should be redesigned to provide the kind of housing the city really needs, to conform to the current Housing Element of the General Plan, which the project presently does not, and to reduce its impacts on traffic, the environment, and the aesthetic elements of its very poor design.