To the Members of the Mill Valley City Council,
I appreciate your efforts to find space for 865 new housing units in our already overbuilt town. I know Mill Valley must continue with the RHNA process, but the numbers are so out of scale with what our infrastructure can safely support that I urge you to explore ways to push back even as you move forward.
Repurposing vacant buildings, second-story spaces over retail, and unused office space is the least impactful way of adding housing; your list includes the potential for 65 of these types of units. Multi-unit housing has wisely been kept out of the high fire hazard areas.
But from the looks of the current Housing Element list, getting to 865 means losing a lot of our local businesses and replacing them with housing. This doesn’t affect the major chains (like CVS) that take up large lots. The state exempts (and privileges) them as outside our jurisdiction, and does not allow us to disrupt their operations.
Without the larger lots of the national chains, the city has resorted to eyeing the smaller lots of local businesses. I took some time to match the non-descriptive addresses on the Housing Element to what was there, and the list shows just how little wiggle room you have; it is peppered with businesses our community can ill afford to lose.
The proprietors I’ve spoken with had no idea that their land was being considered for redevelopment. The owner of Grilly’s and the Malugani property did not know (until I contacted him) that his property, as “underutilized land,” accounted for 11 homes in the Moderate category. He had no interest in such a conversion.
So, local jobs will be lost and replaced with housing — for people looking for jobs? What is a small town without businesses and services? The public rallied behind these local businesses to keep them afloat during the pandemic. That the city has had to put them on this list to make the RHNA shows how severely constrained we are.
Do we really want to consider replacing Goodman’s and Tamalpais Paint with housing, with building materials in such desperate demand? Three of the older auto shops? Happy Feet? The entire strip mall where Sol Food, Sloats, and Doggie Styles are sited? We are already hard-pressed to find affordably priced groceries and services. With an influx of lower income residents, shouldn’t it be a priority to preserve restaurants such as Grilly’s, serving quality, affordable food?
These are locally built businesses which have served the community for years. More than 40 of the 65+ listings are still operating.
I’m sure this wasn’t what you had in mind when you ran for City Council.
The unreasonable mandates are causing undue stress on the city, and it shows here. Is Mill Valley expected to broker deals between landlords and developers? Will the state strong-arm businesses into closing if the Housing Element isn’t certified? Are fines and the use of eminent domain the end game we should expect?
At the same time that the city is targeting parking lots for development, new housing laws limit the amount of parking required for new construction. How will this deficit be mitigated?
Three of our gas stations are also on the list. While there is a current movement to intentionally limit gasoline availability to fight climate change, we still need cars (especially with our inadequate transit system). Low-income residents cannot upgrade to electric vehicles as quickly as more affluent drivers and will be further disadvantaged by fuel unavailability.
Because of our geographical constraints, without cars fire evacuation is greatly imperiled. The Google/MV evacuation simulation took 6,000 cars into account (the RHNA will add 1,000+) and showed heavily managed success for the Mill Valley population of 16,000 (soon to be approximately 17,800). Unfortunately, the simulation failed to consider the fate of the additional 14,000+ unincorporated residents (and potentially thousands of tourists) backed up onto the windy roads of the mountain and out Highway 1.
A California State Audit found the RHNA methodology seriously flawed, and the matter has been referred to the Department of Finance for review. Without confidence in the numbers, the process should have been paused until February, when the report is completed.
Many cities across the state are overburdened with unfunded mandates. Without state backing, developers have no motivation to building low-income housing, especially starting with land that is off-the-charts expensive. If our RHNA exclusively reflected lower income needs, the 580 units requested in the city appeal could be created in the space available without destroying our town. However, this will only work with state subsidies, as lower income housing does not “pencil out” for developers.
The state has shown no willingness to collaborate in this process. Rather than being treated as partners, we are threatened with further loss of control over the fate of our communities. We are at the mercy of private, for-profit contractors (under abysmal economic conditions) to meet the numbers or face grave and irreparable consequences.
The RHNA process has set us up for failure. We can agree that housing is essential, but our unique environmental and geographical constraints have not been appropriately considered. Plan Bay Area 2050 assured us that “one size does not fit all.” Mill Valley’s ABAG appeal, based on profoundly “changed conditions” (including infrastructure, environmental concerns, traffic, flooding and sea rise, fire hazards, and drought) was solicited — and then ignored.
A recent Grand Jury Report excoriated MMWD’s seriously inadequate planning for current population needs, let alone a huge increase. Climate change has changed everything. Most of Mill Valley is WUI or worse, and we are under constant threat of fire. But these hazards, even our lives, are irrelevant to HCD’s methodology.
Last year SCAG granted a reduction of nearly 3,000 units in the city of Pico Rivera, based on an Army Corps of Engineers statement regarding possible dam failure and flooding. There is ample evidence that Mill Valley’s fire danger and byzantine evacuation infrastructure pose a severe risk to residents in the city and Unincorporated Areas. Even with vigilant mitigation, the danger persists. The expert opinions are there. The state will not listen.
There is power in numbers. I hope you are open to participating in an upcoming challenge to the RHNA/HCD methodology. The process has become a bitter, punitive exercise pitting cities and state against each other. We need a collaborative approach to yield real housing solutions. Instead, we next move on to SB 35, and are punished with ministerial approvals, no CEQA, and no community input.
It’s time to challenge the HCD’s right to set housing numbers that are siloed from our new reality. Someone must step in and mitigate this disaster. We need the state to hear us. Instead, we got Newsom’s veto of SB 182 — the only law that would have required improved evacuation routes in areas to be developed — as a reminder that nothing must slow down the housing.
I urge you to join the legal challenge to SB 9, as other cities have done. Pam Lee is the attorney handling this suit. She can be contacted at email@example.com
The state is undermining our ability to plan for a sustainable future. Without pushback, Mill Valley will be reduced to nothing but housing and hazards. Our local democracy is our voice. Please use your voice to protect Mill Valley even as you continue with the RHNA process.
Amy Kalish, Director
Citizen Marin: www.citizenmarin.org