9/24/24 Letter to Marin County Community Development Agency, Planning Division

Written By Anna Trueman

As a direct result of the letter below, the project scope and plan was changed. Equestrian elements have been removed. Trolley plans have been removed, and other plan revisions that better protect the neighborhood.

September 23, 2024

Meghan Altman
Marin County Community Development Agency, Planning Division
Meghan.Altman@marincounty.gov

Dear Ms. Altman,

We are writing on behalf of the North Knoll Neighborhood Association in response to the application for a ministerial review of the housing development project, submitted to the Marin County Community Development Agency on August 5, 2024.

Application: Nijjar Living Trust Housing Compliance Review

Address: Vacant lot at 70 N Knoll Road, Strawberry

Assessor’s Parcel: 034-012-26 and 034-061-09

Applicant: Spirit Residential Group LLC

Date Note Posted: August 21, 2024

After reviewing the proposed plans, we have several significant concerns about the project’s impact on our community, infrastructure, and environment. Below is a summary of our primary concerns, followed by a more detailed discussion.

Summary of Concerns

  • Inadequate affordable housing provision as required by SB 35, with no clear plan to alleviate Marin County’s housing shortage.

  • Steep slopes on the parcel raise concerns about potential instability, flooding, and water runoff management.

  • The project lacks updated reports, including seasonal wetlands and geotechnical assessments, crucial to understanding the environmental and safety impacts.

  • Inadequate sewage infrastructure poses serious health and environmental risks.

  • Increased traffic from construction vehicles will likely deteriorate local roads and pose safety issues.

  • Noise pollution from ambulances, supply trucks, commerce and facility’s ventilation systems will disturb the residential area.

  • Wildlife habitats will be disrupted, particularly those of protected and native species such as deer, hawks, and bobcats.

  • Building aesthetics are out of character with the surrounding community and may contribute to noise from wind and rain.

  • Water pressure issues will negatively impact both the new development and neighboring residents.

  • Inadequate fire safety and emergency plans, including a lack of fire hydrants and horse stall fire mitigation.

  • Parking insufficiencies will lead to street congestion and overcrowding.

Detailed Concerns

Site Survey and Boundaries

We urge the county to conduct an independent site survey to properly define the property lines for both parcels, including adjacent properties at Eagle Rock and Birdsnest Court. The survey must also address easements for fire access, utilities, and county open spaces to ensure compliance with zoning laws.

Equestrian Site Requirements

The site’s compliance with Municipal Code General Standards 22.32.030.A for equestrian facilities is unclear. The plan must account for a 30-foot setback from buildings and property lines and confirm that 1 horse per 1.5–2 acres is permissible.

Senior Facility Proximity and Evacuation Concerns

A senior facility (Kruger Pines Senior & Rehab) already exists within 0.25 miles of the proposed site. This proximity raises concerns about how evacuations will be handled for both the site’s residents and nearby senior residents in the event of an emergency, particularly when considering the absence of elevators in buildings closest to the road. Evacuations for horses and pets must also be planned in detail.

Trash Services, Mail Delivery, Sewage Infrastructure and Water Pressure

Limited detail related to trash pickup and mail delivery. Public service works will not have adequate space and access to complete basic services. The area’s sewage infrastructure is already inadequate, and the project’s plans do not address how it will meet the requirements of Mill Valley Refuge Service. In addition, the local water pressure is insufficient to support the new development, potentially impacting both the new site and existing residents.

Storm Drainage and Flood Mitigation

The steep slopes of the parcel raise serious concerns about stormwater drainage, flooding, and soil stability. The current stormwater drainage system is inadequate, and the project lacks details about bioretention, treated water plans, and retaining walls to stabilize the downslope portions of the property. Flood mitigation strategies must be thoroughly reviewed and detailed. If CEQA is not required, then we request an update peer review & analysis.

Fire Safety and Emergency Plans

We are concerned about the lack of a comprehensive fire safety plan. The Southern Marin Fire Department must approve all final mitigation plans, particularly with respect to ensuring fire hydrant access. The Jensen Hughes report suggests the possibility of using private fire hydrants, and if private water tanks or fire pumps are to be installed, they should be included in the planning documents. Additionally, a no-smoking law should be enforced given the moderate fire danger in the area. Emergency plans should include how memory care patients leave premises.

Noise and Aesthetic Impact

The noise generated by care facility’s ventilation, air conditioning unit, equipment systems, ambulances, medical supply trucks, utility vehicles, and visitors will significantly disturb residents. The proposed driveway is at eye level for residents at 35 Thomas and Birdnest Ct. The wire fencing should meet building codes. Furthermore, the trolley system's noise levels will contribute to pollution, and the mode of transportation (gas-powered or cog-driven) requires clarification. The building’s aesthetics—specifically, insulated metal panels and infill materials—are inconsistent with the neighborhood's architectural style and could increase noise during windy or rainy conditions.

Traffic and Parking Concerns

Traffic will increase significantly, with 325 trips per day projected on N. Knoll Road and surrounding streets, exacerbating street deterioration and congestion. Additionally, the plan does not provide enough on-site parking for workers and residents, and the limited on-street parking will lead to further strain on local streets. The inclusion of only three handicap parking spaces seems inadequate. Additionally, the plans do not detail adequate or any sidewalks for residents and visitors, which is a major concern related to foot traffic & safety. In general, there seems to be insufficient traffic analysis performed pertaining to the surrounding neighbors(N. Knoll, Eagle Rock, Thomas, Central, etc.). There are already limited stop signs in the area, and the site must assess ways to mitigate traffic affecting local residents.

Wildlife and Environmental Impact

The project will disrupt important wildlife habitats, including deer, bobcats, hawks, and tree frogs. Special attention must be given to the hawk nesting season from January to June. Light pollution will also violate Marin County’s night sky initiative, as the development is proposed to have 24-hour visibility. Furthermore, the property is not within ½ mile of public transportation, raising concerns about urban access and sustainability.

Building Materials and Design Issues

The current plans do not adequately describe the roof and balcony materials, nor do they explain how the project will manage the presence of two driveways. Horses' stalls lack fire mitigation plans, and the fencing for these animals is not displayed in the proposal. If therapeutic horse therapy is planned, it should be exclusively for residents, with no public access allowed.

Property Values and Enjoyment

Finally, we are concerned about the project’s potential to reduce property values and diminish the enjoyment of neighboring properties. A multi-family property of this scale will impact the peaceful character of the area, and with the property abutting La Cresta Open Space, it is unclear whether the project meets the 75% perimeter requirement for urban use. A population density study and project square footage to parcel density ratio needs to be made, and a report should be submitted.

Alternate Solution

Given the numerous concerns described above, we strongly recommend and urge the Planning Commission to consider alternative sites like the empty lot where Eagle Rock Rd meets N Knoll Rd and Bay Vista Drive. The 70 North Knoll Rd. site should then become a protected property by county intervention and contribution to preserve and protect it, like the acquisition of contiguous open space from Corte Madera and Tiburon in adjoining areas, the Horse Hill Preserve, due to its proximity to existing county open space and Ring Mountain Preserve.

Conclusion

Due to the significant concerns outlined above, we strongly urge the Planning Commission to require a comprehensive Environmental Impact Report (EIR). This report must include a public review period, followed by a public comment period to ensure community input is taken into account before any approvals are made.

We appreciate your attention to these matters and look forward to your response.

Respectfully,

North Knoll Neighborhood Association

Anna Trueman

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