Board and residents press for fuller review of 99 Marina Drive open space before rezoning

Several members of the Environmental Quality Control Board and multiple residents asked the city on June 5 to treat 99 Marina Drive (Opportunity Site 8) differently from other opportunity sites, arguing the site is a relatively undisturbed open space and merits a project‑specific environmental study before rezoning.

Board member Leonor told colleagues that Site 8 “is really quite different” from the other opportunity sites, which she described as mostly paved or highly disturbed parcels; she said 99 Marina Drive is a naturalized open space used by families and local recreation groups. Leonor said the draft EIR documents 11 special‑status plants and animals at the site but that published bird counts and other sources suggest the EIR’s baseline may undercount habitat and species.

Why it matters: Leonor and others warned that treating 99 Marina Drive as a typical opportunity site risks understating recreational and biological impacts. Under CEQA, an inaccurate baseline can lead to incomplete impact assessment and inadequate mitigation. Leonor recommended the city require a site‑specific EIR for 99 Marina Drive to fully document habitat, recreation use and mitigation needs.

Key points raised: speakers contrasted 99 Marina Drive with the Old Ranch Country Club pipeline (which the city chose to evaluate separately). Leonor said Old Ranch is a groomed golf course and less ecologically valuable than 99 Marina Drive, which is “proximal to our river and our coastal recreation” and is a rare naturalized open space in the city. Other board members suggested options such as reserving a portion of the parcel as open space and permitting development on a reduced footprint.

Process notes: consultants and staff reiterated that any future development application at an opportunity site would require site‑level environmental review and that a programmatic EIR does not by itself authorize construction. They also noted build‑out assumptions in the housing element were set below a full theoretical zoning maximum to reflect realistic development constraints, even though the programmatic analysis used a higher buffer for flexibility.

Next steps: commenters and several board members said they will submit written comments asking for a more detailed biological and recreational baseline, and some urged the city to consider requiring a project‑level EIR for Site 8 if evidence supports it.