The following letter has been sent to the Mill Valley Planning Department, regarding the Design Review Application for the Richardson Terrace development project at 575 East Blithedale Avenue in Mill Valley.
To: Patrick Kelly, Director of Planning and Building
Patrick et al – I reference John Palmer’s email addressed to you and dated January 6, 2021, subject line: Richardson Terrace EIR. I am in complete agreement with John’s commentary and offer the following additions and/or amplifications of several points:
Project History - I was a Planning Commissioner when this project first emerged and participated in the Housing Element Update that identified the property as a candidate for residential development. I know the history and note FAQ 1. from the project website that states:
The project applicant has submitted a new application, which the City has accepted for processing. Previous applications have been withdrawn. However, that does not mean that the City and decision makers are not aware of the extensive history surrounding the project. [Emphasis added]
I would emphasize that the applicant has been consistently tone-deaf and has ignored both community concerns and the extensive history. Former Planning Director Vin Smith stated emphatically that the City had told Mr. Richardson that his recurring proposal (recurring meaning the same proposal resubmitted and resubmitted without change) was unacceptable and that he had to come back with “something different.” So, Mr. Richardson simply waited for a change in Planning Director, a change in City Manager, a change in City Council, and a change in Planning Commission only to submit a “new project” still larger in size (floor area and density), more impactful, and even less responsive to City and community comment - history ignored.
Traffic, Circulation and Parking – In the period this project was last submitted and reviewed, traffic often backed-up to Park School. I recently observed traffic backed-up to Pharmaca, for no particular reason other than traffic volume. The level of service at the intersection has degraded; traffic is more constrained.
The current application exacerbates traffic, circulation and parking conflicts. It just doesn’t work. Aside from the well-documented, historical criticisms, there are new complications. The added density and parking provisions result in a site fully paved building face-to-building face; challenging access and circulation; doubtful emergency vehicle/fire-fighting access and maneuvering area; and a questionable parking plan.
End units have awkward back-out movement patterns and a marginal ability to turn around, if at all. Townhouse parking is tandem, so half the parking requires moving one car to access the second. As problematic and as convoluted as the parking and circulation are, the addition of multiple delivery vehicles, a present day reality, would grid-lock the entire site.
This alone warrants a full EIR.
Neighborhood Fit and Character - There is a wealth of historical commentary addressing neighborhood fit and character. I won’t repeat that here. The current project has missed fit and character criteria entirely. What is most striking is the bizarre mix of architecture – two components, two architects, two completely disassociated “styles.”
In professional terms – it’s a dog’s breakfast. The application’s utter failure to address neighborhood fit and character warrants a full EIR with associated alternatives.
Density - The problem is not density. It would be a mistake to attribute project negative impacts and planning/design failures to “density” alone. The negative impacts and planning/design failures are largely the result of over-burdening the site with too much building area/volume, too much attendant parking and overall building coverage – all the product of unit size, not the number of units. The same number of units could be accommodated in a much smaller, less impactful building(s) if only the unit types were smaller and the mix more attainable/affordable “by design.” Smaller units equal reduced per unit parking required. The problem is unit type and size.
The project is a large-unit market-rate development with a less-than-minimum number of “affordable” units grudgingly forced on a constrained site - constrained by the market-rate units. The project fails to address City housing needs, goals and policies. A full EIR should explore alternative mixes of unit types (product types), unit counts (density) and associated impacts.
Mixed-Use – To call this a “mixed-use” project strikes me as disingenuous. The CN designation permits mixed-use projects with a residential component. One would expect this to mean a commercial development with residential, not a residential development with commercial space at 3.9% of gross building area. The 2,000 sf of commercial space is second-class space located in the “basement” parking level with poor visibility and access. It’s clear to me that the space is positioned to be converted to owner storage.
The project, as designed, simply does not qualify as “mixed-use” in the manner intended. A full EIR should include a credible expectation and demonstration of mixed-use.
The applicant has been dismissive of community and City concerns and has instead incrementally grown the project! A full EIR with alternatives would benefit the process, evidence good planning, and respect the extensive history.
This project is deeply flawed and requires back-to-the-drawing-board thinking.
Burton Miller, FAIA