MEHC Letter of Support for Northgate Mall and DEIR Comments

On March 1, MEHC sent a letter of support for the Northgate Mall redevelopment project and included comments on the Draft Environmental Impact Report (DEIR). You can read it here:

Dear Ms. Talley,

The Marin Environmental Housing Collaborative (MEHC) advocates for projects and policies that advance affordable housing, environmental sustainability, and social justice.

We are strong supporters of the Northgate Mall Project and look forward to seeing it moved forward. Northgate offers 45 underutilized acres that are close to jobs, transportation, and amenities. It is an ideal site for environmentally sustainable, infill housing.

Marin County has a lack of housing options, particularly for the local workforce. This leads to longer commutes in and out of the county for employees across all industries. The creation of housing, particularly affordable and workforce housing, will benefit our environment by reducing vehicle miles travelled each day.

We do want to address various comments we heard on the DEIR regarding the traffic impacts of the project.

One of the strong benefits of the Northgate project is that it is in a transit-rich setting with onsite access to Marin Transit bus routes and directly adjacent to the SMART Civic Center Station. It houses onsite amenities that will reduce the need for driving. However, one aspect of the proposed project is undermining the transit benefits of the project: an overabundance of parking.

As MEHC outlined in a recent Marin Voice (appropriately illustrated with a photo of parking at the Northgate mall), parking abundance is an obstacle to housing affordability and worsens traffic. The best antidote to traffic is investing in alternate forms of transit. Unfortunately, the parking oversupply proposed in this project will hamper the ability to get grants to support transit.

In September 2023, the Metropolitan Transportation Commission (MTC) released their final draft guidance for their Transit Oriented Communities (TOC) policy. In order to be eligible for regional funding, including the One Bay Area Grant (OBAG) program, developments within a half-mile of high-quality transit stations must meet certain residential density and parking requirements. While the development does meet the threshold of 25 units per acre required for commuter rail such as SMART, the development has more car parking than is permitted by the requirements.

For Tier 4 transit stations, the TOC guidelines set a threshold of 1.5 parking spots/residential unit and 4 parking spots/1000 square feet of commercial space. Phase 1 of the project would have 922 residential units and 501,941 square feet of commercial space, yielding a maximum number of parking spaces of 3,391 to be in alignment with the TOC policy. This is 99 spaces fewer than the current Phase 1 parking supply of 3,490 spaces, or roughly an acre of parking.

Phase 2 of the project would have 1,422 residential units and 217,520 square feet of commercial space, yielding a maximum of 2,992 parking spaces to be in alignment with the TOC policy. This is 857 parking spaces fewer than the current Phase 2 parking supply of 3,849. The OBAG program has provided important funds to SMART, City of San Rafael, and other recipients across the County. Given the importance of this development in meeting Marin’s housing needs, we believe that jeopardizing eligibility for OBAG grants would be a mistake. The City should be doing all it can to leverage non-car forms of transit for this project. We recommend that these requirements be met by providing more green space in favor of surface parking in Phase 1, and through reduction in surface parking and/or structured parking in Residential 5 and 6 in Phase 2.

We’re excited about the positive changes the Northgate Mall project will bring, and we appreciate your ongoing dedication to creating a beautiful, functional, modern development for the community. Let’s do the most we can with it to ensure it reduces vehicle emissions.