A complex plan to redevelop Northgate mall in San Rafael has a new wrinkle.

Merlone Geier Partners LLC, the mall’s owner, has submitted a pre-application for an expanded plan to compete against its pending proposal that has already been exhaustively vetted and is undergoing environmental review.

The new plan has been submitted under Senate Bill 330 rules, which entitle the developer to an expedited approval process and prevents city officials from denying the project based on subjective standards.

According to a city statement, “the developer will be conducting a financial analysis on their two project concepts and will choose the one that best fits their needs.”

“Housing developers use SB 330 to make the housing development approval process streamlined and more predictable as there are specific requirements that the City must follow in terms of allowed number of public meetings and review criteria,” city officials wrote in an email.

“The City continues to support the goal to bring housing development forward to address the housing crisis through our regular entitlement review process and the state SB 330 application allowances,” the email says.

Under the SB 330 plan, the developer proposes a number of layout changes that effectively increase the total dwelling count to 1,865, up from 1,422 called for in the original plan.

In a statement, representatives of Merlone Geier said the changes proposed in the SB 330 plan are in response to community comments.

“Essentially, this alternative concept provides another option for consideration as we continue the efforts to bring Northgate back to life,” Ross Guehring, a spokesperson for Merlone Geier, said in an email.

Both proposals call for a 20-year construction project that will bring a mix of homes, shops and restaurants in two phases at the 45-acre site west of Highway 101. The original proposal requires a rezoning, while the SB 330 plan does not.

In response to community concerns about building height, two apartment buildings planned along Northgate Drive as well as the movie theater area would be replaced by townhomes under the new plan. The number of townhomes would increase from 100 to 266, and affordable homes would increase from 146 to 168.

The original plan calls for one building with 96 affordable apartments. Other affordable apartments would also be spread across other buildings. The idea of a standalone affordable apartment building, however, was a sticking point in the original plan for some critics and planning commissioners who worried it segregated the community.

In order to alleviate that concern and to comply with the city’s inclusionary housing requirements, the new proposal would spread all affordable housing throughout the new buildings.

The new plan also repositions 60 townhomes and three mixed-use buildings to the northern and western portions of the site, away from existing homes, the Alma Via senior living center and the Quail Hill neighborhood to calm worries about the density near those areas.

Guehring said many of the community amenities would be included in the new plan, including a town square community space equal to about an acre. The new plan turns this feature into a more pedestrian-focused area by relocating parking away from the central green, another change based on public comments.

“The retail will likely include local and regional restaurants, clothing and boutique retail, and a specialty grocery store,” the developer said in a statement. “We also intend to analyze new options with our movie theater operator for an updated, modern facility within the alternative.”

Meanwhile, the review of the original proposal will continue uninterrupted. City officials are working with LSA Associates to complete the final environmental impact report on the original project, said April Talley, the city’s project manager. The report is a project study required by the California Environmental Quality Act.

At a hearing last month, critics of the proposed redevelopment said a draft environmental impact report of the project failed to fully consider disruptions on the community.

Residents said the project would create more severe disturbances in traffic, noise, emissions and emergency access than the report suggests. Residents urged officials to take a closer look as the final environmental impact report is prepared.

It is unclear if the new plan would be folded into the existing environmental review, or if it would trigger an analysis of its own. The path forward would be determined if and when the developer submits a formal SB 330 application for the new proposal, Talley said.

“At this time, there are no impacts associated with the SB 330 preliminary application as it is a standalone application,” Talley said.

Hearing dates for the final EIR will be scheduled after the document is complete, Talley said.

San Rafael Mayor Kate Colin said the Northgate project is the largest combined commercial and residential project that the city has seen in decades.

“We are grateful that Merlone Geier has welcomed community input since they began the process years ago,” Colin said.

“Their recent submittal of a SB 330 preliminary application is indicative of the very real financial and construction challenges that so many developers in California are facing right now,” Colin said. “I remain optimistic that the formal development application that they ultimately submit will include not only the needed affordable units but also some of the community amenities that our residents desire.”