An environmental document that could pave the way for a major new development in the Strawberry area is now available for public review.
Released Tuesday, the 556-page environmental impact report was more than three years in the making. It scrutinizes the environmental effects of an ambitious project put forward by North Coast Land Holdings in 2020. North Coast picked up the $1.64 million tab for producing the study.
The EIR concludes that the project would result in significant and unavoidable impacts related to greenhouse gas emissions, temporary construction noise and vehicle miles traveled, but that won’t necessarily prevent the project from moving forward.
“An EIR basically assumes that there are going to be significant unavoidable impacts, or there’s a potential for that,” said Tammy Taylor, a county planner.
The project proposes building 336 residences with 859 bedrooms that would replace a majority of the housing at the site. Fifty of the new dwellings would be reserved as below-market-rate housing.
The project calls for construction of a 267,354-square-foot residential care center that would contain 100 independent living and 50 assisted living and memory care apartments, and a 20,000-square-foot building to house a preschool and fitness center.
A 15,800-square-foot addition is also proposed as part of the renovation of an administration building, resulting in a 41,000-square-foot building.
“The housing density for our project remains one of the least intensive uses when compared to surrounding communities while addressing the ever more urgent need for affordable and workforce housing,” Charles Goodyear, a spokesperson for North Coast, wrote in an email. “This project will help Marin County address its requirement under state law to build more housing.”
The most controversial aspect of the project is that North Coast is reserving the right to operate a 1,000-student “college/university” on the 126-acre site, even though the company has declined to reveal its specific plans.
“The size of the school in combination with everything else proposed is going to be something we’re going to look at very carefully,” said Michael Gallagher, president of the Seminary Neighborhood Association. “The developer is not proposing to shrink the size of the school as an offset to the additional housing and the independent living that’s been proposed.”
North Coast acquired the property in 2014 after the Golden Gate Baptist Theological Seminary relocated to southern California. The seminary secured a conditional use permit from the county for a campus operation with up to 1,000 students in 1953. According to the new EIR, the conditional use permit continues to govern the development and operation of the seminary property.
Riley Hurd, the Seminary Neighborhood Association’s attorney, disputes that. Hurd notes that a condition in a master plan for the site that was approved by county supervisors in 1984 stated, “With approval of this Master Plan, the previously approved 1959 Campus Plan Use Permit shall become null and void and be of no further effect or benefit.”
But the EIR asserts that the 1959 campus plan use permit referred only to “road alignments shown in the 1955 Campus Plan, not to the student population or Seminary operations.”
Hurd does not accept this explanation, but says even if the 1953 conditional use permit is the controlling document, it doesn’t give North Coast carte blanche to operate just any kind of 1,000-student institution. He says that is because the county’s planning commission approved the 1953 conditional use permit with the understanding that all of the students would be housed on-site.
“There is no way a meaningful EIR can be conducted without knowing the type of school that is being proposed and its operational characteristics,” Hurd said.
Olivet University, a private Christian university, is the tenant occupying the academic campus. In 2020, when work on the EIR began, Olivet had 100 students. Most of the students and their families live off-site and commute to the campus.
Taylor said the planners who prepared the EIR assumed that a university with up to 1,000 students would be part of the project when calculating the environmental impacts. The EIR, however, appears to discount the idea that an additional 900 students might begin moving or commuting daily to Strawberry if the project is approved.
”Preference for project housing would be given to the student and faculty population, 30 percent of which is expected to live on campus,” the EIR states. “Thus, some of these individuals are already counted among the 530 residents who would live on the project site.”
The EIR notes that San Rafael, Mill Valley, Larkspur, San Anselmo, Tamalpais-Homestead Valley, Corte Madera, Tiburon and several other cities boasting a combined population of 140,000 are within 10 miles of Strawberry.
As a result, the EIR states, “It is reasonably anticipated that most of the students living off-site would already live in this area. Similarly, because of the size of the population within this commute distance, most of the jobs would likely be filled by people already living in the area.”
“For this reason,” the document adds, “a substantial number of students and other individuals would not be expected to relocate to the area in response to implementation of the project.”
Detailing the significant and unavoidable impacts associated with the project, the EIR states that the project would likely be unable to meet the Bay Area Air Quality Management District vehicle-miles-traveled reduction requirements or building decarbonization goals.
“A significant number of housing units would need to be dedicated to campus employee or student housing for the project’s campus to result in more substantial VMT reductions,” the EIR says. “Thus, the proposed residential uses would likely not achieve the required VMT reduction level.”
The EIR also concluded that even with implementation of all practical mitigation it would be infeasible to prevent significant noise impacts during construction.
The EIR presents four alternatives to the proposed development and compares their environmental impacts to the impacts associated with the project. One is a no-project alternative. A second alternative looks at the possibility of relocating the project to other sites in Marin.
A third alternative considers a project that would be consistent with the Strawberry Community Plan, which would allow 324 new/replacement dwellings and 3.3 residences per acre. This alternative assumed that Olivet University would remain on site, allowing enrollment to increase up to 1,000 students.
The fourth alternative would result in several changes to the proposed project. It would relocate the proposed residences on Chapel Hill to lower elevations to reduce local ridgeline visual impacts. It would avoid removal of healthy Monterey pine that may contribute to overwintering habitat for monarch butterflies.
It would relocate some development to address slope stability and landslide hazards, widen Gilbert Drive and Hodges Drive to county standards, and construct a roundabout at the intersection of Seminary Drive, Ricardo Road and Vista Del Sol.
Alternative four would also require a minimum of 90 and a maximum of 100 dwellings to be reserved to serve the university student population onsite and include a new onsite gym that would be exclusively available for use by university students and faculty.
The EIR identifies alternative one, the no-project alternative, as the environmentally superior alternative. It dismisses it, however, because it would fail to meet most of the project objectives. Under state law when the no-project alternative is environmentally superior, an EIR must select a next best choice.
The EIR states that alternative four, which most closely resembles the development proposal, is next best.
“Although the majority of environmental impacts would be similar to those of the proposed project, and no significant and unavoidable impacts would be completely rendered less than significant, the proposed modified development plan would reduce potentially significant impacts related to visual resources, biological resources, slope stability and landslide hazards, and safety hazards and emergency access,” the report says.
According to the EIR, alternative three, which would follow the Strawberry Community Plan, would violate state density bonus law, because it would limit density to 2.1 dwellings per acre.
Among the other alternatives that the EIR considered but didn’t evaluate in detail was a proposal generated in 2019 by a community working group in consultation with North Coast.
This alternative would have reduced the base zoning of the site from 2.47 dwellings per acre to 2.31 dwellings per acre, allowing up to 234 total residences, including 47 affordable residences. The proposal included a residential care center, open space areas, public trails, a fitness center for onsite residents and the Strawberry community, and day care with a maximum enrollment of 60 students. It also assumed university enrollment would increase up to 1,000 students.
The EIR, however, stated that this alternative was infeasible because it also would violate state density law as well as Senate Bill 330, which prohibits local jurisdictions from limiting housing development through downzoning.
The public has until Sept. 16 to submit comments on the EIR. The Marin County Planning Commission will host a public hearing on the document on Sept. 9.
