Marin County officials are expressing frustration with a report designed to evaluate the environmental effects of building thousands of new residences to meet a state housing mandate.
The 700-page environmental impact report analyzes the potential ramifications of additional homes at 79 locations in unincorporated areas. The study considered factors such as aesthetics, air quality, greenhouse gases, historic resources, noise, transportation and utilities.
The state has directed the county to accommodate 3,569 new dwellings in its unincorporated areas by 2031. The county’s list of potential housing sites contemplates 5,214 new homes, the number analyzed in the environmental impact report.
The county paid the MIG firm in Berkeley $1.6 million to prepare the report along with updates to its housing and safety element updates. County supervisors and planning commissioners met Wednesday to discuss the report and take public comment.
The most common type of EIR examines the effects of a specific development project. The new report is a “project” EIR that looks at the changes that would result from all of the proposed sites being developed.
“The EIR identified 15 impacts that are significant and unavoidable,” Rachel Reid, a county planner, told the officials.
These included negative effects on air quality; greenhouse gas emissions; transportation; visual character; water supply and wastewater treatment; noise; and tribal resources.
County planners made it clear that officials are free to approve the housing list despite these impacts, and that they will not even be required to adopt alternatives included in the EIR that would reduce the level of the impacts.
“What the EIR doesn’t do is compel the Planning Commission or Board of Supervisors to take any particular action or approve any alternative to the project,” said Sarah Jones, assistant director of the Marin County Community Development Agency.
“The California Environmental Quality Act acknowledges that there might be important reasons to approve a project or adopt a plan that will result in significant impacts,” Jones said.
Commissioner Margot Biehle said, “So we build on sites that are subject to flooding or wildfires or landslides, that have no access to water or sewer service, or have ingress and egress issues. It just seems all a little bananas to me.”
Several officials and members of the public complained that the project EIR is too complex to digest while lacking the amount of detail needed on specific sites and the context of impacts from local municipalities striving to meet their own state housing mandates.
“We can’t really understand the cumulative impacts because we’re only looking at the projects within our jurisdiction,” said Christina Desser, a planning commissioner. “It’s a very frustrating and expensive process that isn’t going to give useful information.”
The EIR presents three alternatives to reduce the project’s impacts. One, a no project alternative, is considered a non-starter because it would make it impossible for the county to comply with its state housing mandates. The other alternatives appear to present viable options.
The second alternative would reduce air pollution by cutting the number of vehicle miles traveled, or VMT. It would achieve this by reducing the number of remote housing sites in West Marin and locating most of the proposed housing sites within about a 2-mile radius of the Highway 101 corridor, or half a mile on either side of Sir Francis Drake Boulevard.
While VMT, air quality and greenhouse gas effects would remain significant and unavoidable, the second alternative would reduce the impacts by 10% to 15%.
The third alternative would address the significant and unavoidable impacts on water and wastewater treatment in the districts of service providers that lack the ability to accommodate the amount of development proposed.
The EIR notes that North Marin Water District is under an emergency water conservation ordinance that prohibits new water service connections except under limited conditions, and Bolinas Community Public Utility District has had a moratorium on new water connections in effect since 1971.
In addition, Bolinas has a moratorium on new sewer connections that has been in effect since 1985, and the Tomales Village Community Services District lacks a treatment plant capacity to serve new development.
The third alternative would relocate housing sites from service districts that lack capacity to serve new development to areas closer to the “city-centered/baylands corridor,” where water and wastewater service providers have greater capacity.
The third alternative would eliminate the significant and unavoidable impacts to water and wastewater service providers that lack capacity. Nevertheless, the EIR identified the second alternative as the superior option because it would reduce more impacts.
Both the second and third options identify the same three sites already on the list as being the most likely places to shift more housing. Those are a 33-acre parcel at 2 Jeannette Prandi Way near Marin County Juvenile Hall in Lucas Valley; two parcels totaling about 234 acres owned by the Buck Institute for Research on Aging in Novato; and three parcels totaling about 315 acres at the St. Vincent’s School for Boys property.
Under the second alternative, 479 dwellings would have to be shifted to other locations already included in the housing element. That would include 50 residences slated for a site at San Domenico School and 50 at the former U.S. Coast Guard property in Point Reyes Station.
The third alternative would require relocating 896 dwellings. The larger of the two Buck parcels would account for 225 homes. Other sizable sites requiring relocation under this option in the Novato area would include 300 Olive Ave., 58 homes; 805 Atherton Ave., 55 homes; and 791 Atherton Ave., 55 homes. In Point Reyes Station, it would involve 50 homes at 100 Commodore Webster Drive.
“What I was looking for in the EIR and didn’t find is enough information to be able to make some judgment about shifting sites around in the alternatives,” said Don Dickenson, a planning commissioner.
Dickenson cited a number of substantive errors in the report related to individual sites. Some officials at the meeting floated the idea of combining the second and third alternatives.
Dickenson said that the county’s 1st District, which includes Marinwood and Lucas Valley, could end up with as many as 3,000 new dwellings if the homes recommended for relocation under the two options were added to the housing already slated for the district.
Dickenson said the EIR’s assessment of service impacts to the 1st District, particularly to school districts, is inadequate.
“I would find it very difficult to make an informed decision based on the limited information that is actually in the EIR,” he said.
About a dozen people spoke during the public comment portion of the meeting. Many echoed the comments made by officials.
“We’re going to have to build new schools,” said Marinwood resident Stephen Nestel. “The communitywide impacts really need to be discussed.”
Susan Morgan of Lucas Valley said, “I found the EIR nearly incomprehensible. It gives us no information about some of the things we’re very concerned about. For me personally, and I think many people, fire evacuation is a huge concern.”
Ted von Glaun of Lucas Valley said, “When you write an EIR at a program level, see you later. It may meet the letter of the law, but it doesn’t meet the spirit.”
Ken Levin said, “If more people in our communities understood what is being said, you’d be hearing more comments.”
Supervisors Katie Rice and Damon Connolly were absent from the meeting.
The Board of Supervisors will meet on Dec. 6 to decide whether to implement any of the alternatives or certify the project as is.