Hoaxes, a favorite style of political sport for an influential clique of folk fostering local confusions, were in full sway with Woodland City Council on November 3, as it unanimously approved expensive environmental studies for two competing scenarios / options of City growth during the next 20 years.

Woodland City Council wasted a few hundred thousand dollars, overall, for what was termed by City staff and council members alike, as a desired “flexibility” of new general plan, developmental options – adopted to appease Conway Ranch and its coterie of seemingly persuasive local supporters, such as two former two-term mayors, the county schools chief and the Teamsters Union.

Having such “flexibility” is sort of like saying the city may want to fly to the moon, so let’s investigate that option in utter detail – foolishly wasting $120,000 of precious city funds – about the annual cost of a cop on city streets.

As well, the new general plan process needed an efficiently economical focus, not a crazy and wasteful, boondoggle option.  $120,000 represents only a portion of the full municipal cost for such a broadly delirious distraction of city decision-making.

General Plan Realism

Realistically, the new Woodland General Plan (2015-35) should only include new development toward the County Road 25A interchange on Highway 113 and a limited portion of land outside the flood zone north of Kentucky Avenue.

That simple nature of new general plan process and inclusion is very reasonable for the next twenty years or so of city growth, recognizing that the Spring Lake Specific Plan is now only about 35% complete and basic consensus that such infill (to about 80% build-out) takes precedence over opening any land for new development.

For one thing, the city is annually spending a third ($2 million) of its total sales tax revenue to back-fill financial deficiencies regarding retarded development of the Spring Lake Specific Plan, which fiscally leveraged several city capital projects (the Community & Senior Center, Sports Park and upgraded Sewage Treatment Plant).

Post – Spring Lake, developing primarily south toward the Urban Limit Line at County Road 25A (using Spring Lake’s basic public infrastructure), with some development consistent with flood safety north of Kentucky Avenue, encompasses all of the city’s viable new development options on the twenty year planning horizon, period.

Equal Weight, Unequal Value

Propelled by a – “buffaloed” – (please see prior Yolo Sun article) Woodland City Planning Commission, however – City staff swiftly prepared “equally weighed” (similar housing, job and population increases over twenty years) choices / options of direction for City growth and planning.

One of these alternatives features development of ~900 acres at the city’s eastern edge, land owned by the city – exclusively – for the purpose of leasing it to the local cannery as a spray field for its production residues.

This ~900 acres was bought by the city (some of this land obtained from Conaway Ranch) with use of a federal Environmental Protection Agency (EPA) grant, for reason of establishing sustainable treatment related to the waste products of the cannery, a large local employer.

In order to develop this ~900 acres, at all, this federal EPA grant of $2 million would first have to be repaid.

Conaway ‘s Crazy Campaign And Greasy Gambit

Proposed development of this ~900 acres, the subject of a local political (postcard) campaign during 2015, is premised on the incorrect notion (even expressed by city planning commissioners) that the city is under some kind of obligation to discover ways to negotiate with Conaway Ranch, in order to have it provide cooperation for two primary city goals, flood control and railroad relocation.

Conaway Ranch is already legally obligated to cooperate with the city, in all reasonable ways, regarding these two matters (please see prior Yolo Sun article).

Cooperation by Conaway Ranch, regarding flood control and rail relocation, is guaranteed as a part of the Woodland – Davis – Conaway Ranch, surface-water agreement, expected to begin to deliver water to the City in 2016.

Why are city council members ignoring this pivotal fact, entertaining a bogus political campaign based on an obvious hoax?

As well, involvement of the Teamsters Union implies that cannery jobs are at risk, if the city does not act as it desires.  City staff indicate that this view is utter nonsense; while, lack of involvement in this campaign by cannery staff says similarly.

Multiple hoaxes, ingredients of a distinctive scheme of municipal intimidation, are here impelling serious and wasteful city council mistakes – among council members who unanimously ignore both the facts and the involved civic interests.

It’s All About Conaway’s Desire For Commercial Freeway Frontage

Conaway Ranch owns several hundred acres of potential (both sides), freeway commercial frontage, just north of this ~900 acre (spray field) parcel.

To develop these several hundred acres, Conaway needs freeway access.  This 900 acre parcel is the only key to that freeway access, getting new I-5 freeway access ramps to service its (then) potentially quite valuable property.

That’s what all this crazy political campaign is about: Conaway’s lust for a long, double-decker slice of I-5 freeway commercial frontage at the eastern entrance to Woodland.

To get that, Conaway needs to control and cause development of this adjacent ~900 acre parcel – providing the dimension of planning gravity necessary to justify creating new I–5 freeway on and off ramps.

To make that notion in any way plausible, Conaway had to ensure that this ~900 acres was included within the environmental scoping process of the new city general plan.

Of course, Conaway’s dream-come-true would be for the new general plan alternative / option which it dominates, to become adopted by the city council.  Apparently, at least two council votes already exist (please see below, Hilliard and Denny) to accomplish this civic nightmare.  One more council vote, and Conaway could celebrate.

So, Conaway has created a cynical campaign of blatant deception about relevant issues and somehow enlisted a small group of local “heavy-hitters” to express its confusing and deceptive message.  Apparently, about half of these folk have already jumped ship over being manipulated for such connivance.

This cynical campaign was based upon a letter circulated by a former mayor and signed by five other influential local persons, in late 2014; it now appears that only three signatories remain on board the resulting political campaign (one signatory didn’t even know there was such a campaign, when contacted by Yolo Sun earlier this year).

Former mayors Art Pimentel and Marlin (Skip) Davies, as well as county school board chief, Jesse Ortiz, appeared before city council on November 3 to testify on behalf of Conaway.  Plus, local political new-comer, Joe Romero, has taken up its crazy cause.

City Council Synopsis

Woodland Council Member Jim Hilliard easily supported the notion of studying a new general plan, as Conaway desires, because “farmland should be the last to develop,” starkly ignoring the city’s (voter-initiated) Urban Limit Line Ordinance and the stunningly hypocritical fact that he already supports development of a thick slice of prime farmland near County Road 25A.

Any new general plan policy (which both Hilliard and Woodland Council Member Sean Denny clearly appear to anticipate, and upon which Hilliard seemed to presume the agreement of Council Member Angel Barajas) about preserving farm land within the Urban Limit Line plainly conflicts with local voter intent, making any such general plan policy – unlawful.

If members of Woodland City Council desire to install any general plan priority against development of farmland within the Urban Limit Line, that question must be put successfully to local voters on a 2016 ballot referendum.  Let’s see how far such a crazy notion will advance – not far.

So, the third hoax is herein revealed; considering development of these ~900 acres, for any reason about preserving farmland – is total nonsense.

Woodland Mayor Tom Stallard was quoted within the few and diminishing folds of a local newspaper (The Daily Disappointment / The Daily Dinkycrap) to the effect that: “I believe in using data and information to make decisions;” well, by acceptance of the several gleaming hoaxes outlined above, such beliefs are being inconsistently applied.

Civic Transparency?

In recent years, the city (after so many lapses) claims to now be “transparent;” such city council antics as these belie that political pledge.

Here, city council members, on the crude basis of multiple hoaxes and political connivance, are so easily inclined to swallow whatever creepy mess Conaway serves up.

So much for transparency about the facts and policies of public interest – the underhanded fix is in for Conaway Ranch.

Council Member Bill Marble must be familiar with the fact of Conaway signing the surface-water agreement, which guarantees its cooperation with city flood control and rail relocation efforts.  After all, he represented the city in this matter.  However, not a peep was heard from him.

This local semi-daily newspaper (alluded to above) also was reasonably familiar with these twisted and pivotal civic issues and it chose to ignore them; truly, acting as a plain, limp stenographer for a crooked city council and related interests (such as the local Chamber of Commerce) – it usually cannot report its way out of a paper bag, to immense and everlasting community distress.

Stallard (while seemingly knowing better) weakly complained about these sordid circumstances and this huge waste of city money and effort – but then he proclaimed that – “unanimity” – among the city council members was more important than either the facts, good city policy making or the city council’s fair and honorable address to such.

Citizens of Woodland may indeed wonder where this city council culture of compromises, based on hoaxes, will continue to lead.




[Editor’s note: Woodland Planning Commission’s recommendation to the City Council about this item is included within City Council consideration of the new (2015-2035) General Plan, on its meeting agenda for November 3, 2015.]

Native Americans sometimes used a technique for hunting big-game, such as buffalo, by frightening such a herd into stampeding over a cliff.

The term, “buffaloed,” has other pertinent meanings (please see Appendix of Definitions, below), also reflecting an astonishing public event occurring between Woodland Planning Commission and Conway Ranch, in the person of Bob Thomas, its General Manager, during the Commission’s consideration of the new City General Plan (2015-2035) on July 23, 2015.

Conaway’s Campaign

Conway Ranch has instigated a political campaign during 2015, involving colorful and deceptive post cards (Yolo Sun published an article about this campaign:   https://yolosun.wordpress.com/2015/03/21/conaways-skippered-general-plan-campaign-should-be-scuppered/  ), that campaign proponents now say (in July) amounted to slightly more than 3000 cards being delivered to Woodland City Hall.

This campaign matter concerns a 900 acre parcel owned by the city and located at its eastern edge (south of I-5), which is now being leased by the local cannery as a spray-field to disperse wastes created by its operations.

Conaway Ranch (Conaway Preservation Group) owns more than 17,000 acres of eastern Yolo County and several hundred acres adjacent to this 900 acre parcel.

Clearly, Conaway desires to eventually acquire this 900 acre parcel to develop, but the parcel lies within a seriously flood-prone area, requiring a solid flood-control solution prior to any development.

Creating city (new General Plan based) planning attention to this parcel, though, would seem to establish some future civic intention / format, easing / predicating its development — despite the fact city staff has plainly advised that any such future development would be required to produce a (new) General Plan amendment, a specific plan and related environmental studies.

Thomas’ Presentation

Bob Thomas made a lengthy and detailed presentation about this parcel, to the planning commission:

“It’s in your city, it’s in your city limits, [  ] you want to plan that [900 acre] area.

“If this city sends the wrong message to the state and federal government, that it’s not important, we’re not going to fix the flood-control project.

“We’re going to have to make that [flood-control project] work, just like we made the water project work.

“That east area is important to your water supply, [  ] it’s absolutely essential to your flood control and it’s essential for your railroad relocation.

[   ]

“The preferred alternative to relocate the railroad out of your downtown is through Conaway Ranch.

“So, that east area needs to be looked at from a job employment level, from PCP; we’ve solved the water problem, and at this point we can’t throw up our hands and say, we gotta wait ‘til flood control is fixed.

“We should be allowed to go forward with the planning process now, as part of the general plan.  And if we do not have flood control in place, we cannot issue building permits.

[   ]

“[That] 900 acres is not prime ag land.  It’s a policy of the city to preserve prime ag land.

“I don’t know how long it’s gonna take, [  ] but we need to send a strong message to state and federal agencies that we want flood protection.

[   ]

“This [not acceding to our developmental plans] is slamming the door.  [  ] You have the right to proceed with a specific plan for that area.

[   ]

“By delaying the planning process, you’re delaying ultimately what might occur there, I think it sends the wrong message [   ] to federal and state government, that it’s not a priority.

“There’s an opportunity to start the specific plan, while we’re figuring out a flood solution.  They can be parallel processes; they don’t need to be sequential.

“If the city is sending a strong message that it’s land in the city that we plan on developing, [ ] it helps in terms of our federal and state partners.”

Planning Commissioners Respond

Chris Holt, Vice-chair of Woodland Planning Commission, responded:

“Mr. Thomas alluded to it, but I’ll lay it right out there for everyone.

“At some point Conaway has a lot of very good things that we need to solve some of our problems, including the flood control solution, the railway relocation, [and preserving the local cannery].

“So, we would be disingenuous to believe that Conaway would go ahead and give us all of that and not expect something back.

“So, I think that 900 acres and their interest in that 900 acres can be a benefit to us.”

John Murphy, a planning commission member who, like Holt, has been rather slow to respond in agreement with the planning wishes of Conaway Ranch, soon added:

“How do you pay the local share, [for] this?

“That’s the only asset the city’s got . . . the development potential of that property seems to be the funding source [for a flood control solution and rail relocation].

[   ]

“We have to maximize the value of that property, if that means that it has to be in [the new general plan] EIR, then it has to be in it.  I see that’s the only reason we’re even talking about that piece of property, is because of its value to the city.

“Otherwise, I wouldn’t even want to talk about developing that piece of property.

[   ]

“We can develop that piece of property, if it means we’re going to get things we actually want more, which is the flood control and the rail relocation.”

Local Cannery’s Viability Becomes Side-Issue

Thomas made the following comment about the local cannery:

“They would prefer to relocate [the spray field] away from the urban area. [  ] They really can’t make that move unless you include the 900 acres in the preferred alternative. They can’t make that move.  And I would hope that you would honor and respect and want your largest employer to be successful in this city. If it’s not in the preferred plan, they can’t move.”

In other words, Conaway Ranch believes that it controls the only reasonable prospect of relocating the cannery’s spray-field – using its land – thus, making the 900 acre parcel (with general plan zoning) available for acquisition by Conaway Ranch, which would essentially be buying it to provide the city with: (a) government grant-gap funding (~$40 million) likely needed for its flood control project, (b) Conaway’s cooperation with this flood control project and railway relocation.

Planning commissioners seem to be in harmony with Conaway’s view; although, John Murphy (at one point) questioned the necessary connection between moving the cannery’s spray-field and developing this 900 acre parcel.  Thomas failed to respond and the meeting discussion turned away from this issue.

“Growth-Inducing” Planning May Jeopardize Federal Funding

Planning Commissioner Marco Lizarraga made this comment (reflective of his other pertinent comments), echoing arguments by Thomas:

“There’s never enough incentive for the government to fund anything; the more you have, the better and the easier.”

According to city staff, though, the federal government looks askance at local governments using its flood control funding for what it describes as “growth-inducing” purposes, as contrasted with preserving and protecting existing development.  Just imagine the unsustainable, competitive scene, of local governments all across the nation extending their development projects into floodplains, at will, using federal money.

Conaway’s Con

There’s a very basic and serious problem / con regarding Conaway’s view / plan, drawing to attention sometimes strange conjunctions between names and actions (such as with Bernie Madoff).

Conaway is conning (buffaloing) the Woodland Planning Commission, as to the factual circumstances involved in this matter.

An “Agreement For Conveyance Of Real Property And Easements” was entered into by City of Woodland and Conaway Ranch (among others) on December 21, 2010.  This document is the basis for the Woodland – Davis Clean Water Agency, through which these cities will access surface water.

Apparently, Woodland Planning Commission is unaware of this key document, outlining the relevant legal relationship between Conaway Ranch and the City.

As well, Woodland Planning Commission appears to harbor the erroneous impression that the City must make some sort of deal with Conaway Ranch, about this 900 acre parcel, in order to receive its cooperation with flood control and railway relocation.

Article Three (page 8) of this legal document describes the details of obligatory cooperation by Conaway Ranch, with both Woodland’s eventual flood control project and its plans for railroad relocation:


“3.1  Cooperation  CPG covenants to cooperate, in good faith, with Davis and Woodland with respect to matters set forth in this Section 3.1 and to utilize good faith efforts to accomplish the same promptly following receipt of request by the applicable parties. The provisions of this Section 3.1 shall survive the Closing (as defined below) for a period of ten (10) years.

“3.1.1  Relocation of Railroad Tracks  Sierra Northern Railway, a California corporation (“SNR”) has railroad tracks near Conaway Ranch which extend into land owned by Woodland.  Woodland would like SNR to relocate the railroad tracks in a manner which reduces the impact on street traffic in Woodland and in order for that to occur, the relocated railroad tracks may include replacement railroad tracks through Conaway Ranch.

  • Subject to the provisions of Sections 3.2 and 3.3 below, CPG agrees to cooperate, in good faith, with Woodland’s reasonable efforts to have SNR relocate its railroad tracks by providing necessary right of way and construction easements to SNR for the relocated railroad tracks, to the extent they are placed on Conaway Ranch.
  • These easements will be granted, if at all, without payment from SNR to CPG so long as (i) CPG does not incur any direct costs in connection with the grant of such easements; (ii) SNR bears all costs and expenses associated with such easements; and (ii) SNR complies with the provisions of Section 3.4 below.

“3.1.2   Woodland Flood Protection   The Parties acknowledge that Woodland desires to improve flood protection for its City by increasing the flood capacity of Cache Creek by relocating the south levee of the Cache Creek Settling Basin and constructing a new channel south of such levee.

  • Subject to the provisions of Sections 3.2 and 3.3 below, CPG agrees to cooperate, in good faith, with Woodland’s reasonable efforts to implement such flood protection by conveying appropriate easements over Conaway Ranch located within the Cache Creek Settling Basin for the location or relocation, maintenance and operation of the necessary levees and the right to flood the areas north of such levees. These easements may cover approximately 550 acres of Conaway Ranch within the Cache Creek Settling Basin.
  • These easements will be granted, if at all, without payment by Woodland to CPG so long as (i) CPG does not incur any direct costs in connection with the grant of such easements; (ii) Woodland bears all costs and expenses associated with such easements; and (iii) Woodland complies with the provisions of Section 3.4 below.

[   ]

“3.2   Impact on Conaway Ranch   CPG shall not be obligated to provide any of the easements described in Section 3.1 if, in the exercise of CPG’s good faith business judgment, supported by substantial evidence of the same, such easement would have a material negative impact on the operation of Conaway Ranch or the marketability of the crops grown on Conaway Ranch as a whole.  [This section continues, outlining potential “effluent” / “pipeline” concerns and creating a process of non-binding mediation for potential conflicts.]

[   ]

“3.4   Terms Applicable to Easements Granted Pursuant to Section 3.1   The following provisions shall be applicable to each and every easement granted pursuant to Section 3.1 above:

“3.4.1   Diligent Construction   Once the grantee of such easement commences construction of the improvements to be located within its easement area, such grantee shall diligently prosecute the construction of such improvements through completion.

“3.4.2   Compliance With Applicable Laws   The grantee of such easement shall, at its own expense, comply with all laws applicable to the construction and operation of the improvements constructed in and the use of such easement.

“3.4.3   Provisions in Section 2.4   The provisions contained in Section 2.4 shall also apply with respect to each easement granted pursuant to Section 3.1.  Specific terminology shall be conformed to the terminology of the specific easement.

[   ]

“2.4   Coordination With Ranch Operations; Crop Damages; Restoration   [This provision is self-explanatory, concerning notice of and responsibility for potential crop damage, due to granting of relevant easements.]”


Conaway Ranch is legally obligated to perform according to this “Agreement For Conveyance Of Real Property And Easements.”

It is not necessary for Woodland to attempt to sway Conaway Ranch’s potential bad faith actions regarding these matters (flood control and railroad relocation), by prematurely planning development on the 900 acre parcel of city owned land which it is intent on acquiring.

Woodland Planning Commission’s decision to accede to the wishes of Conaway Ranch, by expanding the new general plan process to include planning for this 900 acre parcel, was obviously based upon a gross misunderstanding of affairs, based on Bob Thomas’ con-job of mischaracterizations.

Appendix of Definitions for the word: Buffaloed —

Cassell Dictionary of Slang contains the following entry for ‘buffaloed’: 1900s-1950s [orig. U.S.], coerced, crushed. [BUFFALO v.] This is the entry for ‘buffalo’: 19th C. [U.S.] to overawe, to frighten, to confuse

The American Heritage Dictionary of the English Language, Third Ed. has this to say: buffaloed 1. To intimidate, as by a display of confidence or authority 2. To deceive, hoodwink 3. to confuse, bewilder

DICTIONARY OF AMERICAN SLANG offers the following: BUFFALO verb 1) [about 1879] To confuse someone purposely, especially in order to cheat or dupe 2) [about 1890] To intimidate; cow; bulldoze

HISTORICAL DICTIONARY OF AMERICAN SLANG has relevant insights: BUFFALO verb Originally Western 1a) To intimidate or frighten, especially by means of mere bluff; to cow.


[Editor’s note:  California Environmental Quality Act processes involve Environmental Impact Reports for significant development projects, in general, with a time period for written public comment about proposed projects, such as the Prudler Subdivision (186 low-density dwelling units on the ~40 acre, former expansion site for County Fair Mall, adjacent to Woodland Community & Senior Center on southern East Street).  The prior article presents Yolo Sun’s basic Comment.  This Supplementary Comment by Yolo Sun details objections to impacts of the proposed project upon County Fair Mall and regarding City sustainability policies and City housing policies and practices.]

October 23, 2015; Page 1 of 4

From:  Bobby Harris  [Yolo Sun]

To:  City of Woodland, Community Development Department, 300 First Street, Woodland CA 95695

Re:  Prudler Project Draft EIR (Supplementary Objections)

I’ll raise several supplementary objections to append with my commentary document filed on October 21, 2015:

The site of the proposed project is the expansion site for County Fair Mall.

Though no longer perceived as expandable, County Fair Mall remains intrinsically connected to this site, currently because its future growth space has since evolved into a prominent, potential element of its conservation.

This relationship must be recognized and applied within land use decisions regarding this (expansion) site, especially in the contemporary moment, while the future viability / nature of the Mall is quite tenuous / uncertain, with existence of very substantial / significant environmental consequences related to these evolving conditions.

As indicated within my prior document of objections, there exists a genuinely valuable mixed-use contour / relationship between County Fair Mall and its former growth site.  Such vital recognition / expression triggers the imperative need for a comprehensive analysis and evaluation of the potential influence of increased residential densities within this (expansion) site, alongside an examination regarding improved / intensified physical connectivity between these two, long associated parcels.

Limiting (to low) residential densities on this (expansion) site would result in significant and irreversible environmental effects, related to the future nature and viability of County Fair Mall.  Increased density alternatives for any residential development of the proposed project site must thus be examined, analyzed and considered within the Draft EIR.

October 23, 2015; Prudler Project (Supplementary Note); Page 2 of 4

Adjacent to the city’s East Street Corridor Specific Plan (and should have been included within in it; why it is not, is strange), future development of this site has huge and undeniable effects upon such city planning efforts; these effects must be addressed, examined, analyzed and considered within the proposed project’s Draft EIR.

Efficient, attractive and environmentally sustainable (pedestrian, etc.) access between County Fair Mall and increased density residential development upon this site would create a stronger ‘neighborhood focus and identity,’ presently lacking from the Mall’s profile.  Such a key dynamic would naturally reach into the nearby portion of Spring Lake Specific Plan.

North of the Mall, there exists state property (the county fairgrounds) which eliminates any creation of such a key commercial dynamic: close proximity.

County Fair Mall (and by some good measure, civic interests) would greatly benefit from its ability to enhance its commercial scope through such a dynamic of ‘neighborhood focus and identity,’ since its days of being at the cutting edge of major local commerce have long waned / been eclipsed.

Accomplishing such important and comprehensive public and private benefits, demands that increased density residential alternatives to the proposed project be examined, analyzed and considered in a draft EIR; the current EIR entirely fails to address these fundamental city planning issues.

It seems that this 40 acre site was oddly (erroneously) left aside as irrelevant, when composition of the relevant (urban corridor) city specific plan was created, leaving it to crazily fall through the planning-cracks and appear in the distinctly unsuitable posture of now being proposed as the same sort of low density residential zoning, of which the city has quite tremendous oversupply — as contrasted with the unique civic and private values clearly achievable (one way or another) upon this particular site.

Another example of this site falling through planning-cracks (of various sorts) is reflected by the fact that so much of my comment is directly relevant to basic issues of implementation of the city’s Urban Limit Line Ordinance, consideration of which is unlawfully absent from this Draft EIR.

October 23, 2015; Prudler Project (Supplementary Note); Page 3 of 4

Persons eventually residing within this site are at walking distance from both, responsive commercial access and access to regional Yolobus service (eliminating need to transfer from feeder-routes).  Higher density residential development is obviously an authentic value for these specific planning circumstances and such value extends to environmental effects that are not addressed, examined, analyzed or considered in this Draft EIR.

When SACOG updates its “Blueprint” for sustainable regional communities, it might well be expected that this specific site would easily be targeted for the sort of higher-density transportation / commercial hub, which is so widely promulgated by “smart-growth” planning principles.  Of course, presently, this site is not even considered by SACOG as legitimate “infill.”

Something is plainly wrong with planning of the proposed project site being processed as “infill” — outside of the contemporaneous General Plan (2015-2035) Update — while it clearly represents such potential and important values, in terms of city sustainability policies of its Climate Action Plan (noted in initial document of objections), environmental values and options likely to become recognized by the updated SACOG “Blueprint.”

These particular circumstances are environmentally pivotal; yet, because the proposed project’s Draft EIR lacks a higher residential density alternative, there is within it no address, examination, analyses or consideration of these key environmental circumstances or effects; this Draft EIR is starkly deficient, attempting to circumvent adopted public environmental policy and processes at local, regional and state levels.

Dovetailed into these serious problems are general issues regarding the city’s vast imbalance between low residential density housing / zoning and higher residential density zoning opportunities (noted at item (e) of document of objections).  Continuation of this adverse housing density imbalance by the proposed project, surely means that higher residential density opportunities must eventually become located within other (perhaps less desirable or less environmentally sustainable) locations.

This circumstance illustrates the sound-planning reasoning adopted by local voters (2006) within the city’s Urban Limit Line Ordinance, (lawful) reasoning which is being recklessly (unlawfully) ignored by this Draft EIR.

October 23, 2015; Prudler Project (Supplementary Note); Page 4 of 4

Environmental effects / impacts certainly occur as a result of contrasting / differential locations of lower and higher density residential developments.

This Draft EIR fails to address, examine, analyze or consider these serious, cumulative and irreversible environmental effects / impacts, caused by the proposed project’s perpetuation / extension of an enormous disparity between low and high density residential development.



[Editor’s note: This formal document of objections to the Prudler Project Draft (California Environmental Quality Act) Environmental Impact Report will be filed with City of Woodland on October 19, 2015.]


October 19, 2015; 6 pages, Items (a) – (h)

From: Bobby Harris

To: City of Woodland

City of Woodland, Community Development Department

300 First Street, Woodland CA 95695

Re: Prudler Project Draft EIR

I raise the following objections to the Prudler Project Draft EIR:

(a)  The mixed-use alternative is obviously unreasonable, appearing to be simply a – “straw-man” — used to leverage exclusion from consideration of a higher density alternative — which it is absolutely essential to examine.

A prominent “project objective” is not to compete with County Fair Mall, which has submitted a letter in support of the proposed project (and would not have done so if there was any valid reason (via City Hall) to believe that commercial zoning would become any significant aspect of it).

Truly — the actual mixed-use character of this overall situation is readily seen: County Fair Mall is the commercial element, while its (equal, former) expansion area occupies the residential component of a mixed-use format.

The pivotal question is: What level of residential zoning density is optimal?

Mall owners will swiftly say: The formula for basic success is maximization of residential densities nearby their location.  Higher residential densities at the relevant site would be supportive — if not transformative — of the actual, realistic success of County Fair Mall, the future of which remains clouded.

Environmental effects upon County Fair Mall of adopting some higher-density residential alternative at the site of the proposed project have not been addressed, analyzed or considered by the Prudler Project Draft EIR; they must be.  Environmental effects regarding future viability of County Fair Mall must be examined in relation to potential zoning decisions involving a range of residential density alternatives of the proposed project.

Prudler Project Draft EIR; October 19, 2015; page 2 of 6 

(b)  Environmental effects / impacts of the proposed project upon phased build-out of Spring Lake Specific Plan must be carefully delineated and considered, including its influences regarding basic financial elements of the Plan.  Declining rates of housing build-out and sales within the Plan will adversely affect the city’s economic planning and bonded indebtedness, as well as affecting the Plan’s capabilities to provide intended aspects of public infrastructure and facilities.  Adverse environmental effects / impacts upon Spring Lake Specific Plan will result from the proposed project; these effects / impacts remain unaddressed and unanalyzed by the Draft EIR.

(c)  Processing the proposed project as an amendment to the existing General Plan, in the face of the General Plan Update process, appears to be predicated on an erroneous perception that the site constitutes “infill,” in planning jargon.

This project does not represent legitimate “infill;” rather, it sits distinctly upon the utter municipal periphery (although possessing important urban significance, totally denigrated by the proposed, low-density style of this project).  Only the city’s civic facilities separate it from undeveloped land.

As well, the SACOG “Blueprint” for sustainable communities in this region does not recognize this site as representing proper “infill,” (“. . . does not include capacity projects within the vicinity of the [proposed] project;” please see Draft EIR, p. 229).

Also, the proposed project abruptly conflicts with key sustainability percepts of basic city planning policies, such as represented within its Climate Action Plan (please see pages 23 and 24 of document, regarding land use topics – Strategy T/LU-2: Infill Development, Redevelopment, and Repurposing; Strategy T/LU-3: Smart Growth in New Development).

Strategy T/LU-2 indicates that the city’s Urban Line Ordinance (see below) clearly applies to the irreversible environmental effects / impacts of the proposed project; yet, there is no evidence that it has been applied.  Implementing a (2006) ballot-based ordinance, it would seem justified that such city process / policies should not be occurring under-the-floorboards.  Formal, comprehensive address to contexts of the proposed project, within the city’s planning ambit of the Urban Limit Line Ordinance, is imperative.

Prudler Project Draft EIR; October 19, 2015; page 3 of 6

(d)  Not yet implemented (apparently, until the new 2015-35 General Plan), an Urban Limit Line Ordinance was adopted by Woodland voters in June of 2006.  It would seem plain that local voters did not intend a near decade-long delay in implementation of such basic planning law.

This ordinance establishes that: “[T]he City shall continually reevaluate residential land use densities, housing policies and zoning to determine the potential for increased residential densities for both infill sites and undeveloped land within the permanent urban limit line.  The City shall continually review existing non-residential zoning to determine potential for conversion to higher density residential uses within the permanent urban line.”

There has apparently yet been no municipal planning process, at all, related to implementing this ballot-based ordinance, regarding the proposed project, which is intended for location upon a unique and key peripheral site.  And of course, both prongs of this voter-installed planning ordinance have been fully relevant to this site, since it has for decades been zoned as commercial.

“[C]ontinually reevaluate” would seem to indicate that such determination would occur at least upon each successive project concept / application pertaining to such a unique and key site as the proposed project.  This legally-binding municipal ordinance, however, has apparently never been implemented for purposes of: “[D]etermin[ing] the potential for increased residential densities,” regarding the land involved with proposed project.  As noted in (c), above, basic city policy demands such implementation / application, involving irreversible environmental impacts.

Foreseeable environmental consequences of the proposed project, such as its irreversible impacts / effects regarding present, future implementation of the city’s Urban Limit Line Ordinance, alongside a range of (reasonable and relevant) alternative developmental scenarios, are obviously intended to be included within CEQA analyses.  The city’s Urban Limit Line Ordinance makes (lawfully) imperative such inclusion and analysis within the Draft EIR, of an increased density alternative for the Prudler Project.

Prudler Project Draft EIR; October 19, 2015; page 4 of 6

(e)  As outlined within objections (already within the Draft EIR, p. 230) by Legal Services of Northern California to the proposed project, the city has a glut of low density zoning / housing and a dearth of higher density zoning opportunities.  Objections to this project by Legal Services indicate that:

“The proposed Prudler Subdivision would add to the very large surplus of above-moderate and moderate income units, while failing to address the City’s obligation to rezone land to accommodate very low and low income housing units.  The City should be encouraging higher density development to address the significant shortfall, as required by housing element law.  The proposed project is inconsistent with the city’s Housing Element, further exacerbating the surplus of above-moderate income units, and its negative impact cannot be mitigated.”

Continuation of such vast imbalance between low and higher density zoning, within the proposed project, clearly contains various environmental effects / impacts remaining unaddressed and unanalyzed by the Draft EIR.

These critical / key, local housing issues, should properly become topics within the current process of General Plan Update, rather than allowing the proposed project to side-step / circumvent such profound matters, using an amendment to the decades-old, existing General Plan.  Prematurely acting (with no good civic reason) to consider / approve the proposed project, also results in environmental effects / impacts within that fundamental process; these effects / impacts remain unaddressed and unanalyzed.

(f)   City of Woodland’s General Plan Update (2015-2035) is presently being accomplished.  The relevant site is located on a principally urban, developmental and transit corridor, southern East Street.  This corridor has its own City Specific Plan, environmental effects / impacts upon which, by the proposed project, remain unaddressed, unanalyzed and unconsidered.

The relevant site is adjacent to: County Fair Mall, Yolobus’ city transit-hub, Woodland Community & Senior Center (and Sports Park) and Spring Lake Specific Plan.  Adverse environmental effects will result from prematurely acting to approve the proposed project, prior to completion and adoption of the new City General Plan, within which this site must become integrated.

Prudler Project Draft EIR; October 19, 2015; page 5 of 6

The existing General Plan and Spring Lake Specific Plan are based upon planning assumptions of the relevant site being zoned for commercial uses (please see Spring Lake Specific Plan, p. 8-1).

Alteration of such key zoning must be consolidated within comprehensive processes of the current General Plan Update, not prematurely addressed through such a proposed, tardy amendment to the existing General Plan.

Various alternatives for future development of this important site must be comprehensively identified, analyzed, evaluated and considered within the current General Plan Update.  Adverse environmental effects / impacts will flow from premature action upon the proposed project, considering and approving it, while these effects / impacts of such premature approval upon the General Plan Update process remain unaddressed and unanalyzed.

(g)  Park space within the proposed project is a subject of serious shame.

City standards require 3.35 acres of park. However, this project will provide only 1.38 acres, expecting to mitigate this huge deficiency by providing the remaining — required park space – somewhere else, outside of the project.

Such a mitigation scheme is totally unreasonable.  Park space is relevantly meaningful to inhabitants of this proposed project — only to the extent that it is properly sized and convenient.  Buying park space somewhere else, likely so these developers can expand profit margins within this project — will not serve to satisfy serious needs of this projects’ dwellers for properly sized park space; such residents will plainly be sorely distressed by a park less than half of the size it should be (according to city standards).

Mitigation is not reasonably applied in this circumstance, leaving the great majority of park space required by the proposed project, to be located at an unknown and likely, greatly inconvenient distance from the persons who need to use it.  Are folk supposed to jump into motor vehicles and drive to park space being provided through such an adverse mitigation scheme?

A point of support(?) has been raised, that this park will also be used by residents of the nearby portion of Spring Lake Specific Plan.  A special “pass-through” element has been included within the proposed project, to expedite use of this already far too small park, by Spring Lake residents.

Prudler Project Draft EIR; October 19, 2015; page 6 of 6

The proposed project’s entire park space scenario is wholly unreasonable, with a cumulative nature of environmental effects / impacts which have not been addressed, analyzed or considered within the Draft EIR.

Park space of 3 acres, while deferring a third of an acre to another location, might have been reasonable – given good cause; but, the present situation of park space within the proposed project is obviously unreasonable, untenable and must be rejected.

(h)  I incorporate by reference, as if fully set forth herein, prior Yolo Sun articles available on the internet (Jan. 24, 2014; Feb. 2, 2015; Sept. 28, 2015; Oct. 14, 2015) about the proposed project.




[Editor’s note: The following is an Open Letter from Yolo Sun to Woodland Planning Commission Members.]

Woodland Planning Commission Members:

Thanks so much for retaining the planned four-lane roadway on East Street, south of Gibson Road, despite the Prudler Project developers desiring its downsizing.

As you could see from my prior (personal-type) email to you, though, I’m not agreeable with your unwillingness to request an increased density alternative for the draft EIR of the Prudler Project.

[The Prudler Project proposes low density residential development on the ~40 acre vacant parcel, located between County Fair Mall and Woodland Community and Senior Center.]

I understand that you may be confused about what’s really up with this matter; your proper action does necessitate a justified deviation from “typical” (as the project consultant stated) situations, in a sort of ‘contrary to general expectations’ manner.

I had hoped, however, that my recently published letter to you may have sufficiently alerted you to these several subtleties.  But, no progress resulted.

Also, I’m seriously wondering whether you have properly reviewed the relevant material, and if you did so, whether you might well have been raising many very serious questions and issues revealed therein.

I’m hoping that upon such a review and consideration of the city’s Climate Action Plan, its Urban Limit Line Ordinance and (already filed) substantial objections to the Prudler Project and its draft EIR — you may indeed decide to request a greatly needed, increased density alternative.

Here are links (and a Yolo Sun excerpt) to relevant material about the Prudler Project :

*  Woodland’s Climate Action Plan (please see pages 23 and 24 of this document, regarding land use topics — Strategy T/LU-2: Infill Development, Redevelopment, and Repurposing and Strategy T/LU-3: Smart Growth in New Development) —


*  Draft EIR for Prudler Project (please see pages 175 – 199, 229 – 231 (counting total pages in this huge PDF file — document cover, table of contents, etc. . . . ; mouse on scroll button should reveal exact pages) :


*  Relevant excerpt from previous (Jan., 2014) Yolo Sun article :

___  Urban Limit Line Ordinance  ___

Not yet implemented (apparently, until the new 2015-35 General Plan), an Urban Limit Line Ordinance was adopted by Woodland voters in June of 2006.

It would seem plain that local voters did not intend a near decade-long delay in implementation of such basic planning law.

This ordinance establishes that: “[T]he City shall continually reevaluate residential land use densities, housing policies and zoning to determine the potential for increased residential densities for both infill sites and undeveloped land within the permanent urban limit line.  The City shall continually review existing non-residential zoning to determine potential for conversion to higher density residential uses within the permanent urban line.”

There has apparently yet been no municipal planning process, at all, related to implementing this ballot-based ordinance regarding YRI’s project, intended for location upon a unique and key peripheral parcel.

And of course, both prongs of this voter-installed planning ordinance have been fully relevant to YRI’s land, since it has for decades been zoned as commercial.

“[C]ontinually reevaluate” would seem to indicate that such would occur at least upon each successive project concept / application pertaining to a unique and key parcel such as YRI’s land.

This legally-binding municipal ordinance, however, has apparently never been implemented for purposes of: “[D]etermin[ing] the potential for increased residential densities,” regarding the land involved with YRI’s project.


Brief Argument

Prudler Project consideration surely should await the city’s current process and eventual adoption of a new General Plan.

There is absolutely no civically responsible reason to be in a hurry.

Political and legal consequences will certainly flow from your choosing such an adverse course of project approval, please believe me.

Why this Project is now moving forward, at all, in the face of / ahead of the new General Plan, is not obvious, except that the locally well-connected George Phillips of Loomis (a former collaborator with Paul Petrovich) is its agent / applicant.

The city already has a large oversupply of low density housing (and a large undersupply of higher density housing opportunities; please see Legal Services attorney comments (two letters, one of specific recent objection to this project, the other highly critical of the city’s Housing Element) within pages of draft EIR, noted above).

Development of this key parcel must be considered in relation to the Urban Limit Line Ordinance, in conjunction with the General Plan update — not strangely (greasily?) moved and approved otherwise – unwisely ahead of such key processes.

City planning staff are improperly describing this parcel as “infill” (please see pertinent remarks of SLSP’s attorney, Pioneer Law Group, within draft EIR comments of objection, noted in pages identified, above).

This project does not represent legitimate “infill;” rather, it sits distinctly upon the municipal periphery (although possessing important urban significance — which is denigrated by the proposed project).

CEQA demands consideration of a “range of reasonable alternatives . . .” to any project.

The city and developer are attempting to skirt the spirit / letter of this law by including an unreasonable ‘straw-man’ alternative of mixed (commercial-residential) use, when project objectives outline noncompetition with County Fair Mall — and not including an increased density alternative (reasonably) required to be considered consistent with the city’s Urban Limit Line Ordinance — a pivotal component within any reasonable analysis of future land use within the city.

Foreseeable environmental consequences of the proposed project, such as its impacts / effects regarding implementation of the city’s Urban Limit Line Ordinance, alongside various (reasonable and relevant) alternative developmental scenarios, are obviously intended to be included within CEQA analyses.

The city’s Urban Limit Line Ordinance makes (lawfully) imperative such inclusion and analysis of an increased density alternative for the Prudler Project.

The project consultant clearly advised the Planning Commission at its last meeting (- predicated by my initial open letter to it, published below -) that it could properly request / demand consideration of an increased density alternative, but you didn’t do it.

I strongly suggest that you now do the following:

(a)  Carefully review and consider the relevant material provided above;

(b)  Submit comments / objections based thereon, timely to the city;

(c)  Upon the final EIR being presented in November, demand that it be recirculated with an increased density alternative.

Bobby Harris

Yolo Sun


The new Yolo County Courthouse has just celebrated its “grand opening.”

On August 24th, Yolo Sun published a letter to state and local officials responsible for Americans With Disabilities Act (ADA) compliance at the new Yolo County Courthouse.

In this letter (please see earlier article, below on blog scroll), we detailed numerous violations and deficiencies with disabled parking and route of travel to the new courthouse.

Since writing that letter, a number of the issues we raised have been addressed — but others remain.

Judicial Council of California has sent a reply letter (please see below).

Two Sets Of Stop Signs

Based on our letter, the City of Woodland has installed stop signs on Lincoln Avenue at Sixth Street to help protect pedestrians, including the disabled, travelling from both parking lots to the courthouse.

However — somehow overlooked — was our letter’s indication of necessary installation of stop signs at the intersection of Oak Avenue and Sixth Street.  Yolo Sun has again requested city action.

The city greatly needs to install stop signs on Oak Avenue at Sixth Street to protect pedestrians using the 171 courthouse parking spaces located in the more distant of the two public parking lots, as well as pedestrians — including disabled persons — who must (are directed to) there cross Sixth Street from the closer parking lot.

As of today, the city has still not done so.  The new courthouse is filling these lots on a near-daily basis.  How long does the city intend to delay the imperative installation of this second set of stop signs?

Reply Of State Judicial Council

Construction of the new courthouse was financed and overseen by the state-level Judicial Council of California (JCC), which bears primary responsibility for its ADA compliance.

Published below, is the reply letter received from the JCC, promising to rectify several of the deficiencies we raised.  For example, it has promised to add one ADA-required, van-accessible disabled parking space, found missing from the original courthouse allotment.   JCC also promised to add signage at the parking lot across from the Police Station to discourage jay walking on Sixth Street, which pedestrians will be tempted to do to avoid as much as an extra block of travel distance between that lot and the courthouse.  Neither of these promised improvements has yet materialized, but we suppose JCC can be taken at its word and these remedies will soon be forthcoming.

Unfortunately, JCC’s reply fails to correct the most serious problem facing disabled persons traveling from their parking spaces to the courthouse – namely, the two and a half to three block distance they have to negotiate, as well as facing traffic hazards along the way, passing across two busy driveways (for the courthouse and the police station).

No Solution Yet Provided

JCC’s letter of reply addresses these concerns about unreasonable distance and hazards faced by the disabled – related to potential ADA violations — but without providing any satisfactory solution.

Our letter to JCC outlined several potential solutions, such as leasing parking for disabled persons from the large lot of Woodland Joint Unified School District (directly across Sixth Street from the courthouse).  Believably, this lot already has new signage disinclining casual parking by courthouse visitors — disabled or not.  Leased parking arrangements would allow the courthouse to direct disabled persons into this much closer lot; while, expanding regular parking within its lots several blocks away.

Other potential solutions also exist, for bringing disabled persons within a reasonable distance of travel from the courthouse door.

Yolo Sun will continue to act, monitor and report on these issues, as well as continue to seek solutions for these courthouse deficiencies.

_ _ _ _ _ _ _ _ _


_ _ _ _ _ _ _ _ _

From:  Judicial Council Of California

September 4, 2015

Re:  New Yolo County Superior Courthouse (Courthouse)

Dear Mr. Harris

Thank you for your interest and concern relative to Americans Disabilities Act (ADA), and its applicability to the above Courthouse as expressed in your letter to the Judicial Council of California (JCC) ADA coordinator, Ms. Linda McCulloh. I would like to advise you that the plans for this building were developed under the regulations set forth in the 2010 California Building Code (CBC), and the accessibility requirements in the CBC while in conformance with the ADA, in some instances are more stringent. As with all of our Projects, the plans for this project were submitted for approval to the compliance unit within the Division of the State Architect (DSA). We received such approval prior to construction.

Despite receiving such approval, the safety and concern for all of the visitors to the Courthouse is paramount for the Judicial Council of California, as well as the local Court. Prior to establishing the parking lots that you describe, much effort was made to determine that their location and path of travel was as close as possible to the entrance to the Courthouse. Obviously, as in many downtown areas, there is a limit to the number of sites available. In the case of this project we were able to find sites that did provide a path of travel over new and existing sidewalks. Unfortunately, we did not control or have the ability to clear a path of travel through the Railroad Museum site, contiguous to the northern boundary of what you refer to as “Lot A”.

However, notwithstanding the above DSA approval, and in support of making accessible accommodations as convenient as possible, we are in the process of adding one van accessible space parking space in “Lot A”. We also requested the City of Woodland Public Works Department to review the placing of stop signs at Sixth Street and Lincoln. After completing an engineering study, they have installed a stop sign at that location. We are also in the process of placing signage directing the pedestrian path of travel to hopefully preempt jaywalking. Other potential parking spaces are dependent on their availability and the City of Woodland’s enforcement policies over which we have no control.

Again, thank you for your interest in this matter and we will advise you when the additional space is available.


Loren “Mike” Smith, Project Manager

Judicial Council of California



Honorable Kathleen M. White, Presiding Judge, Yolo County Superior Court

Mr. Shawn C. Landry, Court Executive Officer, Yolo County Superior Court

Mr. Matt Rexroad, Chairman, Yolo County Board of Supervisors

Mr. Patrick S. Blacklock, County Administrator, Yolo County

Mr. Tom Stallard, Mayor, City of Woodland

Mr. Paul Navazio, City Manager, City of Woodland

Mr. Martin Hoshino, Administrative Director, Judicial Council of California

Mr. Bill Guerin, Director, Capital Programs, Judicial Council of California



(Editor’s note — this is an Open Letter to City of Woodland Planning Commission.)

City Of Woodland Planning Commission Members:

The 38 acre Prudler Project (on East Street, adjacent to County Fair Mall (CFM)) is coming before you next Thursday, based on a September EIR from Raney Planning and Management, Inc..

As you are aware, the California Environmental Quality Act (CEQA) requires consideration of a “range of reasonable alternatives to the proposed project” (CEQA Guidelines Section 15126.6[a], [f]), which may “substantially lessen” its various environmental effects.

For the Prudler Project, there are a mixed-use Environmental Impact Report (EIR) alternative and a reduced density EIR alternative — both of which are relatively suspect choices for EIR alternatives — since continued commercial zoning on this parcel (once set aside for a “Phase Two” of CFM (ponder that)), has already, long been generally dismissed; as well, the Prudler Project “Objective” of “not competing” with County Fair Mall — is directly contradictory to any re-installation of commercial zoning on this parcel.

Also, Project developers have no good reason for wanting to reduce density below 5 units per acre (to 3.3/acre), nor any good reason to believe the city will ever insist on an even lower density than what they desire.  While this particular alternative should indeed (for planning perspective) be included and considered, it is essentially a second EIR-alternative strawman, alongside the mixed-use alternative.

These are pretty curious choices for an EIR alternatives analysis; since: Where is the increased density EIR alternative?!

Although obvious that the reduced density alternative will create less environmental effects – short term – it is not so clear that this is the case – long term.

In fact, this very (city planning) subject has arisen before.

Urban Limit Line Ordinance

City voters have long ago adopted an election ballot measure creating an Urban Limit Line Ordinance.

Providing profound gravity for the imperative of including an increased density EIR alternative of the Prudler Project, is the fundamental need to address the city’s Urban Limit Line Ordinance, so as not to be leaving expanding problems and issues of the (even currently) urgent need for higher densities . . . off into an unknown future — which is an apparently unanalyzed environmental effect / impact of this Project.

The city’s Urban Limit Line Ordinance is a (2006) ballot derived measure, directed to: Ensuring that the city is continually evaluating the potential for increased residential densities within all significant projects, such as the Prudler Project.

Certainly, such voter originated policy should not be (somehow) implemented under the city floorboards (as I’ve previously been advised by city planning staff, may indeed be occurring); rather, implementation / application of this Ordinance must be a formal component / element related to all significant residential (or commercial) projects.

A decade has passed since the city’s Urban Limit Line Ordinance was voter-adopted; yet (perhaps somewhat due to economic conditions), it has not seen the light of day within city policy until the currently active (2035) re-iteration of the city’s General Plan.

Apparently, there is no reference, at all, to the city’s Urban Limit Line Ordinance within the EIR for the Prudler Project.  Application of this Ordinance would obviously have fostered inclusion of an increased density alternative within the EIR for the Prudler Project.

Prudler Project Objectives

All Prudler Project “Objectives” (possessing significant legal recognition under CEQA) would plainly be in harmony with consideration of an increased density version of EIR alternative.

Local ballot-based law mandating such consideration, with project objectives being consistent, involving such a relevant / pivotal parcel (please see below) — all three facts argue for the presentation of an increased density EIR alternative.

Yet, it was not included within the Project EIR.  Could this odd lacuna be due to the Project proponent (developers) simply not wanting to have, to consider or to properly evaluate any increased density alternative?

A mixed-use EIR alternative was included for consideration, despite the fact that it sharply conflicts with Prudler Project “Objectives”, likely included because the developers anticipate its being found unacceptable, alongside the reduced density alternative, simply strawman types of alternatives, not essentially competing within the overall EIR analysis — against the developers’ desired project concept.

“Alternatives analysis” is the primary foundation / vehicle / venue of public policymaking under CEQA and reasonable comportment demands consideration of truly reasonable alternatives, not strawman alternatives which actually displace genuine and proper alternatives, such as, in the present situation – due to absence of consideration of an increased density EIR alternative.

Key Parcel For City Urbanization

This parcel occupies a very key location, between CFM and the city’s civic complex & sports park, adjacent to the city’s East Street Corridor (Specific Plan Area) — long directed toward attempting to advance proximate urbanization.

As well, this parcel is very easily accessible to public transportation — quite nearby the very hub of local and regional bus service at CFM, with convenient, regular routes passing by it on a daily (~hourly) basis.

With about 70% of Spring Lake Specific Plan yet to even be built out: Why does this city need yet another round of such low density, Spring Lake type development upon this key, easily urbanizable parcel, a parcel so clearly susceptible to the longstanding zoning percept of promoting the “highest and best use” of property?

Such a civically useful, higher density EIR alternative seems to have been carefully avoided, because of city catering to these recent developers; when, this original project (a first foot in the door, regarding altering what was long ago perceived as excessive commercial zoning nearby CFM) was focused upon —  fairly affordable — senior housing (for which there remains a great local need).

The existing range of EIR alternatives for the Prudler Project is unreasonable.

City In Concert With Developers, Attempting CEQA Circumvention

The city is attempting to again (along with the example of Spring Lake Central Project, now the subject of preliminary litigation for similar reasons) unlawfully promulgate a broad and essentially unexamined (by CEQA EIR) expansion of: Low density, large lot development (for the wealthy), which so very few folk can afford, exacerbating our locally pivotal homeownership divide.

Seriously adverse and unlawful zoning decisions will exist, by the Planning Commission accepting this starkly flawed Prudler Project EIR, which is positioned directly against the city-designated concept of promoting: “Life-cycle housing,” set forth within the (adjacent and here quoted) Spring Lake Housing Element,  reflecting General Plan principles.

Fiscally, would not the city make added (needed) development fees by approving increased densities?

According to city officials, the city loses about $100,000 per acre by lowering densities from 15 to 8 units per acre.  If the city goal is to raise development-fee revenue, why is it not considering an increased density EIR alternative for the Prudler Project?

All things considered, we have a suspicious and untenable situation involved with Planning Commission consideration of the present (flawed) EIR for the Prudler Project, since it lacks an increased density alternative, which would “substantially lessen” (CEQA Guidelines Section 15126.6[b], [c]) numerous, overall, long-range, environmental effects / impacts (such as related to: city infrastructure efficiencies, public-transportation / pedestrian accessibility, public-transportation reinforcement, preservation of open space, compact development (lesser sprawl), important issues of CFM commercial viability, provision of affordable housing and affordable homeownership, etc.), as well as formally and properly implementing the city’s Urban Limit Line Ordinance.

You must reject this flawed Prudler Project EIR and direct city staff to prepare a lawfully acceptable EIR, which includes an increased density alternative.


Bobby Harris


Woodland City Council has provided millions of dollars of developer subsidies at Spring Lake Specific Plan, millions of dollars which would otherwise be required to be spent for affordable homes within the Plan.

These city subsidies, millions of dollars going into developers’ pockets, involve its affordable housing program and inclusionary zoning ordinance.

Alongside these massive and questionable city subsidies, a municipal code section directly related to these matters has mysteriously disappeared; while, transparency is clearly achieved regarding the city’s stark equivocations about the feasibility of affordable homeownership at Spring Lake.

Two Spring Lake Projects’ Inclusionary Zoning Postures

Woodland City Council approved two Spring Lake projects on May 5, 2015.

Spring Lake Central Project is 105 aces, with 375 single-family homes and 232 apartments on 9 acres; Cal West – Optimistic Partners Project is 45 acres, with 225 single-family homes, 190 of which are counted for purposes of the city’s inclusionary zoning law (Municipal Code Chapter 6A-5-20).

Inclusionary zoning, also known as inclusionary housing, is an American term which refers to municipal and county planning ordinances that require a given share of new construction to be affordable by people with low to moderate incomes. Woodland’s ordinance allows the City Council to adopt a proportion of either 10% or 20%; currently, 10% is the law.

With a slight concession, in the midst of receiving immense and unreasonable city largesse, the developers of Spring Lake Central Project accepted that 41 affordable homes must be provided at the revised Project, since it was reducing overall residential densities.

Cal West – Optimistic Partners Project is required to produce 19 affordable homes.

In-Lieu Fees And City Housing Issues

What’s known as “in-lieu fees” can be paid by developers – in lieu of – building affordable homes — if the city “demonstrates” with “substantial evidence that there is no feasible alternative” to using such fees, in other words — that affordable homes are not feasible to construct and sell.

However, the city has not engaged in any such “demonstration” of “no feasible alternative” to these in-lieu fees (Municipal Code, Chapter 6A-5-20(d)).  The city has failed to respond to repeated requests by Yolo Sun for whatever material (“substantial,” according to city law) evidence exists to believe the city has made and adopted such a formal “demonstration” of the infeasibility of affordable homes in Spring Lake.

The city has created a sliding-scale formula for assigning in-lieu fees, matched to housing densities, resulting in $1.59 million in funding which the city intends to use for facilitation of rental-housing projects, in direct violation of numerous provisions and regulations of the Spring Lake Housing Element (please see prior Yolo Sun article regarding legal Notice to Woodland City Council).

$1.59 Million For Rentals, Or $8 Million For Affordable Homes

The city’s inclusionary zoning law uses an outdated illustration of its mandate, relating the requirement of spanning the “affordability gap,” then estimated to be ~$100,000, based on a home cost of $250,000.  Cost of Spring Lake Central homes will begin around $450,000; so, today’s “affordability gap” would probably be more like $200,000 and up.

41 affordable homes would easily amount to well over $8 million of mandated developer resources required to be used for affordable home construction at Spring Lake Central Project.

Instead, Woodland City Council has chosen to accept only $1.59 million of in-lieu fees from these developers, for illegal use with rental-housing projects, based on obvious, numerous and fundamental violations of city law.

Thus, the city has lost about $6.4 million on this deal, overall, although unlawful prioritization of rental-housing greatly aggravates this situation.

Feasible In One Project, Proven Infeasible In The Other?

Interestingly, the Cal West – Optimistic Partners Project has an “option,” approved by the city council, of either paying in-lieu fees or building affordable homes.

In other words, the city council believes that affordable homes are indeed feasible within a nearby location at Spring Lake — just not in the Spring Lake Central Project — where it must be “demonstrated” as infeasible to lawfully collect $1.59 million of in-lieu fees, which the city desires for its (unlawful) use to promote rental housing.

Well, which is it, feasible or infeasible?

Also, how is it that Cal West – Optimistic Partners Project can ride the legal fence with inclusionary zoning?

City law requires that only it (the city) may initiate use of in-lieu fees and only where affordable homes are proven to be infeasible.  Here, the city seems to have (unlawfully) delegated to developers its basic authority, improperly ceding to developers’ “option,” its own role of determining the feasibility of affordable homeownership.

Clearly, legal inconsistency appears in this situation.  In-lieu fees being allowed, piecemeal, while the feasibility of affordable homes also exists — directly contradicts the city’s inclusionary zoning law.  The city is playing fast and loose with its housing law.

Transparent prevarication by the Woodland City Council is surely revealed by such multiple, bald equivocations about the feasibility of affordable homes at Spring Lake.

City Disappears Key Code Section

Alongside these calamities against public interest, is the fact that a directly relevant municipal code section (to in-lieu fees) has simply disappeared.

The missing code section is: 6A-3-50(B)(2)(a).  Inquiry to the city clerk indicates an empty folder, where the paper copy of this section would / should be, and it is not listed within the city’s municipal code.

Yolo Sun has repeatedly requested the city to resolve this strange mystery, to no avail.

This key code section is specifically referred to within the Spring Lake Housing Element as being the basis for city determinations that affordable homes are somehow found “not suitable” in a particular project; but where, “there is certainty that the required units for which the in-lieu fees are being paid will actually be built on a designated site in the proximate area, in a timely fashion consistent with the Ordinance and Specific Plan.” (Spring Lake Specific Plan Housing Element, Regulation 3-6.)

Since the city intends to use this $1.59 million from Spring Lake Central Project for the (clearly unlawful) purpose of facilitating rental housing, such a municipal code provision would be a hard obstacle.  Of course, the city has attempted to avoid a dense fabric of other obstacles, by simply ignoring them; perhaps, this one more was too many.

The question is: What actually happened to this key code section?

It has not been repealed and plainly was once on the books.  Its disappearance is fairly suspicious, as well as potentially affecting in-lieu fee related housing policy recently adopted by the city council.

It was pivotally referred to in the city staff report relevant to removal of the 50-unit (project) cap from the overall ordinance process for in-lieu fees.

Until June, 2014, city law recognized that use of in-lieu fees within large projects would defeat the basic purpose of inclusionary zoning.

Based on this disappearing code section, city council action erasing this 50-unit cap, if challenged, would likely become null and void.


This self-explanatory Notice (per state Government Code Section 65009(d)), prepared by Yolo Sun‘s editor, is filed with City of Woodland on September 8.

Legal process involved, is that the City has 60 days to respond to this Notice; thereafter, its causes of action will accrue and 180 days are allowed to file a formal lawsuit.



September 8, 2015; Page 1 of 8

NOTICE IS HEREBY GIVEN — Pursuant to California Government Code Section 65009(d) — Woodland City Council approval of the Spring Lake Central Project is in violation Government Code Sections: 65913(a)(2, 3), 65913.2(a), 65864(b), 65866 and 65867.5(b).

This NOTICE specifies in pertinent detail issues raised by City of Woodland resident, Bobby Harris, within his testimony expressing general concerns and disputes about its deficiencies regarding affordable homeownership, related to Woodland City Council action on May 5, 2015, approving an adversely revised / amended Spring Lake Central Project.

Specification of Deficiencies

Deficiencies include:

(a) Imposition of planning design criteria (Government Code, Section 66418(5, 9)) for purpose of “rendering infeasible” development of proper dwellings for economic segments of this community requiring / desiring affordable homeownership (Government Code, Section 65913.2(a));

(b) Imposition of planning design criteria (Government Code, Sections 65913.2(a), 66418(5, 9)) for purpose of disabling and circumventing City of Woodland’s inclusionary zoning ordinance, wherein such developmental infeasibility (item (a), above) triggers collection of in-lieu fees (Woodland Municipal Code, Chapter 6A-5-20(d)(1)), intending the unlawful diversion of in-lieu fees thereby obtained (involving multiple violations of Spring Lake Specific Plan Housing Element; please see Descriptive Narrative, below), from supporting provision of local affordable homeownership opportunities, to uses outside of the legal nexus for such fee collection, assisting local rental-housing development;

Notice to Woodland City Council

September 8, 2015

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(c) Failure of City of Woodland to make a “diligent effort” (Government Code, Section 65913(a)(2, 3)), through its administration of land use and developmental controls and the provision of regulatory concessions and incentives, to significantly reduce housing development costs and thereby facilitate the development of affordable homeownership;

(d) Elimination from the Spring Lake Central Project of zoning categories for 15 and 20 dwelling units to the acre (item (a), above), the only zoning categories reasonably accessible / available for affordable homeownership;

(e) Avoidance by the City (item (a), above) of feasibly using “small lot development” (Woodland General Plan Housing Element, pp. 80-81), the City’s use of which is purportedly designed / intended to increase feasibility of affordable homeownership by significantly reducing development costs;

(f) Violation by the City’s Spring Lake Central Project Development Agreement, of Government Code, Sections 65864(b), 65866 and 65867.5(b), resulting from item (b), above.

Descriptive Narrative

“The SLSP [Spring Lake Specific Plan] is intended to be a ‘life-cycle’ community,” indicates its Housing Element (Section 3 of the Plan): “Life-cycle housing” means that “people can, theoretically, remain in or near their neighborhood their whole life[, through]: “Diversity in housing stock[.]”

“Life-cycle housing [leading the SLSP Housing Element’s presentation] makes good business sense,” it continues; “[b]y tapping many market segments, land absorption occurs more rapidly, which is a factor in increased developer profit. Diverse housing creates its own demand as families move up through the market. [  ] The social network (what is often referred to as ‘small town’ atmosphere) can remain intact, as children, adults and seniors all live within a neighborhood.”

This Notice pertains to the fact that Woodland City Council approval of Spring Lake Central Project starkly abandons this basic SLSP percept.

Notice to Woodland City Council

September 8, 2015

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The SLSP Housing Element plainly states (p. 3-5) that: “Since the multi-family / single-family split is already built into the Specific Plan planned land uses, the affordability requirements are achieved on [  ] a project-by project basis, based on the density category of the project.”

Thus, SLSP projects must be independently designed expressions of its central theme of establishing “life-cycle housing.”  Obviously, Spring Lake Central Project fails to satisfy this “intention” of SLSP Housing Element, because it extinguishes all opportunity for affordable homeownership.

Moreover, collection of in-lieu (of building affordable, for-sale homes) fees is being formulated and designed for diversion away from opportunities for affordable homeownership, toward municipal support for rental housing.

Woodland City Council has violated Woodland Municipal Code, Chapter 6A-5-20(d)(1), by failing to satisfy its fundamental provision: “Only the city may initiate this in-lieu fee option and only where it is demonstrated based on substantial evidence that there is no feasible alternative.” (Emphasis added.)

There exists no such infeasibility “demonstrat[ion] based on substantial evidence,” related to City of Woodland’s inclusionary zoning ordinance and policies to create affordable homeownership.

Thus, Woodland City Council approval of Spring Lake Central Project also violates SLSP Housing Element Regulation 3.6, which demands such a “demonstrat[ion],” as well as mandating : “[C]ertainty that the required units for which the in-lieu fees are being paid will actually be built on a designated site in the proximate area, in a timely fashion consistent with the Ordinance and Specific Plan,” contrary to the city’s plan of in-lieu fee use for rental housing.

Purportedly, the SLSP Housing Element “encourages the construction of [affordable] types of housing products, rather than traditional ‘garden-style’ apartments, which are often the only type seen in multi-family densities.” (SLSP Housing Element, p. 3-6.). This policy fails, due to items (a) and (b), above.

Notice to Woodland City Council

September 8, 2015

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With regard to affordable homeownership in a “life-cycle community,” SLSP Housing Element Regulation 3.8 is also violated by Woodland City Council approval of Spring Lake Central Project: “Notwithstanding whatever programs / methods are ultimately used to implement the affordable housing obligation, the required end result is that the calculated number of affordable units will be built in a timely fashion and be spread throughout the Plan area, including throughout each neighborhood.”

Specifically noting affordable homeownership opportunities, SLSP Housing Element Regulation 3.11 demands that: “The affordability requirement for each project [ ] is to be met on the project site to the greatest feasible degree.”

Since Woodland City Council approval of Spring Lake Central Project has violated its Municipal Code, Chapter 6A-5-20(d)(1), by failing to satisfy its fundamental provision: “Only the city may initiate this in-lieu fee option and only where it is demonstrated based on substantial evidence that there is no feasible alternative[,]” (emphasis added), such approval clearly violates SLSP Housing Element Regulation 3.11.

In addition, SLSP Housing Element Regulation 3.14 is violated by Woodland City Council approval of Spring Lake Central Project: “Affordable units shall be the same ownership-type as the base units that generate the need (e.g., for-sale for for-sale, rental for rental).”

Woodland City Council obviously contemplates using in-lieu fee money, derived from for-sale units, for application to rental units, by approving a particular formula for this purpose, plainly abridging the requirement of Regulation 3.14, about no mixing of “base units” (for-sale / rental units).

Such an unlawful purpose of in-lieu fee diversion displays a prominent motivation: Establishment of an unlawful ‘slush-fund,’ to be used at the utter discretion of Woodland City Council, for the purpose of fiscal support for various rental housing projects, under influence of meeting its regional housing allocations under adverse circumstances created by the State of California’s repeal of redevelopment authority.

Notice to Woodland City Council

September 8, 2015

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Spring Lake Central Project starkly fails to embody the bedrock objectives of SLSP Housing Element — (H-1)  “Offer housing for all segments of the population;  (H-2)  Offer a true mix of types of housing product and density of housing.”

SLSP Objective (H-2) — emphasizes — that there must be a “true” mix of housing product and densities, not the inadequate mix of expensive homes and “garden apartments,” approved within Spring Lake Central Project.

Fundamentally creating and controlling these multiple violations, of the SLSP Housing Element and of Woodland Municipal Code, Chapter 6A-5-20(d)(1)) is: Deficiency (a), above: Imposition of planning design criteria (Government Code, Section 66418(5, 9)) for purpose of “rendering infeasible” development of proper dwellings for economic segments of this community requiring / desiring affordable homeownership (Government Code, Section 65913.2(a)).

Lot and unit size and configurations are, of course, paramount to providing affordable housing. Minimum lot sizes within SLSP are 2904 square feet (R-15) and 2178 square feet (R-20/R-25) (minimum lot widths of 30 and 40 feet). By the city’s “small lot development” regulations, however, these apparently minimum lot sizes seem limited to only “small lot subdivisions,” likely not useful for dispersing smaller units into a “true mix” of housing products, as intended by SLSP Housing Element (Objective H-2). Minimum unit size is 850 square feet. Maximum lot coverage is 50%.

Contrast these SLSP requirements with the minimum lot size under Los Angeles’ Small-Lot Development Ordinance: 600 square feet, with a 16 foot widthMaximum lot coverage is 80%. Such pivotal innovations are implied by the Housing Element — in its rhetoric, but missing in its process.

It is indisputably evident that City of Woodland has imposed design criteria, “render[ing] infeasible” all reasonable ability for development of affordable homeownership in Spring Lake Specific Plan and its (SL) Central Project. Affordability is, at its root, governed by lot size and coverage and unit size.

Notice to Woodland City Council

September 8, 2015

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The SLSP Housing Element (p. 3-6) outlines a “wide range” of zoning, from three to twenty-five units to an acre, which “will enable a variety of housing products.”  However, within all zoning categories reasonable for affordable homeownership, such products are limited by design criteria (lot size and coverage and dwelling size), unlawfully “rendering infeasible” this provision of the Housing Element (Government Code, Section 65913.2(a)), directed to ensuring all economic sectors / interests of the community have access.

SLSP already deviates from the citywide goal of 35% (lowered to 29%, to accommodate added “estate-style” homes) of units being within the “multi-family” categories (15 -25 units to an acre), the only residential zoning categories reasonably accessible for affordable homeownership.

This deviation is accomplished by use of a fee-based fund on housing projects, resulting in the creation of 74 “off-site” rental units. (SLSP Housing Element, pp. 3-2, 3-3, 3-5, 3-8, 3-10.)  In this regard, a broader platform of inclusionary zoning at SLSP has already been significantly compromised, (pre)-shifted toward lower densities, with less room for affordable homes.

Spring Lake Central Project represents a total abandonment of affordable homeownership, predicated on violations of city law and policies related to the key concept of “feasibility,” by unlawful imposition of design criteria.

Also, “Because of the features built into the Plan to increase affordability “by design” [  ] the City has concluded that the market will result in moderate income units without the need for specific requirements in the Plan. As such, Plan achieves consistency with the General Plan with regard to moderate units through development regulations and site-design requirements.” (SLSP Housing Element, pp. 3-3, 3-5, 3-6.)  References here appear related to rental housing, not to affordable homeownership.

Apparently, homeownership for anyone not within upper-income economic classes, has become infeasible; while ironically, the city purports that its “design” criteria will somehow “increase [ ] affordability.” Design criteria and feasibility are inextricably relevant to affordable homeownership, of course.

Notice to Woodland City Council

September 8, 2015

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Here involved, is the fact of the city’s relevantly fundamental design criteria: (a) minimum lot size, (b) maximum lot coverage, (c) minimum unit size, all adversely contributing to thus unavoidable practical circumstances, wherein affordable homeownership has been “render[ed] infeasible,” obviously contrary to the intent of Government Code, Section 65913.2(a).

Such “infeasibility” of affordable homeownership, though, while thus caused by the city — also has been unlawfully assumed by the city — with its blunt abridgement of its municipal code (Chapter 6A, noted above).

The city is “rendering infeasible” affordable homeownership at Spring Lake Central Project, through its imposition of unreasonable design criteria in violation of state law, in a way which also violates the city’s bedrock housing law and policies relevant to “feasibility” of development of affordable homeownership.  One may even reverse the arbitrary (and capricious) order of these tightly interwoven legal calamities.

It appears that: If Woodland City Council had ever actually undertaken, in earnest, to provide the nature of formal City “demonstrat[ion],” demanded by its own housing ordinance, such an exercise would tend to reveal the profound failure of its essential design criteria to perform toward facilitating affordable homeownership, and such a paradigm shift of understanding may have predicated reform, as moved within instant causes of action.

Feasibility of local homeownership and governmental accountability merge as goals of instant causes of action, in harmony with state law.

Additionally, another compound state law – city law violation exists, in that Government Code Sections: 65864(b), 65866 and 65867.5(b), which govern city development agreements, require that such agreements be consistent with local law / ordinances. Since the city has violated its municipal code (Chapter 6A), through its Spring Lake Central Project Development Agreement (by unlawfully invoking collection of in-lieu fees), as well as violating its housing policies and regulations, directly relevant violations of state law accrue in conjunction with instant causes of action.

Notice to Woodland City Council

September 8, 2015

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Acceding to development agreements which violate city policies and state law likely involves multiple motivations for the city – (a) establishment of a ‘slush-fund’ for use in meeting its regional housing allocations with respect to rental housing; (b) accelerated collection of SLSP development fees connected to overleveraged debt, presently paid by annually using about $2 million (a third) of city sales-tax revenue; (c) general and various local pressures to best accelerate long-overdue SLSP development, in order to eventually move forward subsequent city developmental plans / intentions.

However, although thus motivated to accelerate SLSP development, according to senior city officials, altering zoning from 15 to 8 units an acres, as occurred within this adverse revision of Spring Lake Central Project, actually loses the city about $100,000 per acre in development fees.

Both the city and Spring Lake Central Project Developers have distinct motivations related to using design criteria for “rendering infeasible” development of affordable homeownership. Although SLSP’s Housing Element declares that the concept of “life-cycle housing makes good business sense,” these developers are strongly wedded to out dated, traditional, cookie-cutter, subdivision formats and strongly disinclined to productively receive purported “encouragement” from the city toward up-dating their views — especially when city rhetoric is gravely undermined by imposition of design criteria “rendering infeasible” such very development.

Conflict over such relevant design criteria, between the city and Spring Lake Central Project developers, is thus no (essential) ingredient of the city’s violation of Government Code Sections 65913(a)(2, 3), 65913.2(a). Imposition of unreasonable (and unlawful) design criteria by the city, in the context of development of affordable homeownership, with assent and collusion of relevant developers, might even be of a more common mold, than that of city – developer conflict.  Either way, it injures public interest.

Inclusionary zoning is a valuable tool for civic equity and social cohesion of communities; it is not a convenient fount of funds to further what is fast evolving into a fundamentally, structurally reinforced, economic chasm within our community.



The new Yolo County Courthouse is scheduled to begin initial operations on Monday, August 24, 2015.

However, an investigation by Yolo Sun has discovered a number of serious, even glaring deficiencies related its compliance with the Americans With Disabilities Act (ADA).

These deficiencies have recently been brought to the attention of relevant officials at various levels of responsibility for the new Yolo County Courthouse, by means of the six-page letter from Yolo Sun‘s editor, published below:

August 19, 2015


Ms. Linda McCulloh

ADA Coordinator

Judicial Council of California

455 Golden Gate Avenue

San Francisco, CA 94102-3688


Ms. Julie Ann Burton

ADA Coordinator

Yolo County Superior Court

725 Court Street, Room 102

Woodland, CA 95695


Dear Ms. McCulloh, Dear Ms. Burton:

With the new Yolo County Courthouse scheduled to officially open next week, I want to bring to your attention some serious deficiencies made in parking for disabled persons. These deficiencies include violations in the number of disabled parking spaces; distance from disabled parking to the Courthouse; and serious pedestrian traffic hazards between the parking lots and the Courthouse. I believe all of these issues involve violations of the Americans with Disabilities Act (ADA).

For recipients if this letter who may not be familiar with public parking for the new Courthouse, let me describe the layout. The Courthouse itself fills the entire block on Main Street in Woodland between Fifth and Sixth Streets. The Courthouse faces Main Street and a secure, employee parking lot is directly behind the building. The Woodland Police Department fills the entire block directly south of the Courthouse.

Public parking for the Courthouse is provided in two separate lots located on Sixth Street two and three blocks south of the Courthouse. Land for


these lots was purchased from Union Pacific Railroad and is situated on the opposite (east) side of Sixth Street from the Courthouse. Lot A is closer to the Courthouse and is on the north side of the intersection of Sixth Street and Oak Avenue. Oak itself is two blocks from Main Street. The second Lot B is still farther from the Courthouse south of the intersection of Sixth and Oak. Public disabled parking for the Courthouse has been consolidated for both lots in the southwest corner of Lot A.

Following are the perceived deficiencies with the disabled parking that is being provided:

Violation of number of spaces for persons with disabilities

The ADA allows disabled parking for separate lots to be grouped together in one lot so long as the number of spaces is determined according to each of the separate parking facilities. The Courthouse has done this and is providing a total of eight disabled parking spaces in Lot A. Seven of these are regular disabled parking spaces and one is van accessible. However, based upon a total of 65 parking spaces in Lot A and 171 in Lot B, the ADA requires a total of nine disabled parking spaces for both lots (three for Lot A and six for Lot B). Furthermore, the ADA also requires that one of every six disabled parking spaces, or fraction thereof, must be “van-accessible.” Lot A contains only one van accessible parking space and based upon nine overall spaces, Lot A is supposed to have not one, but two, van accessible spaces. So, the Courthouse needs to add one more disabled parking space and it must be van accessible.

(See: Section 208.2 Minimum Number of Parking Spaces; 2010 Standards for Title II and III Facilities: 2004 ADAAG—ADA Accessibility Guidelines for Buildings and Facilities; also ADA Update: A Primer for State & Local Governments. US Department of Justice, Civil Rights Division)

Unfortunately, this oversight cannot be corrected by simply restriping one of the existing disabled spaces. Van accessible spaces require wider space alongside the van, as well as direct access of a designated width to a sidewalk so as to avoid people in a wheelchair having to travel in traffic areas and behind parked vehicles.


Distance from Courthouse

As noted above, disabled parking is located in the southwest corner of Lot A, at the corner of Sixth and Oak. This places it a full two and a half blocks from the entrance to the Courthouse. While the ADA does not prescribe fixed distances between disabled parking and the building it serves, it does say that “(p)arking space that serves a particular building…shall be located on the shortest accessible route from parking to an entrance….”

(See: Section 208.3 Location; 2010 Standards for Title II and III Facilities: 2004 ADAAG—ADA Accessibility Guidelines for Buildings and Facilities)

Considering that disabled persons typically suffer from mobility and respiratory problems, requiring them to walk two and a half blocks does not seem reasonable. In fact, most disabled persons will have to walk even farther than two and a half blocks, since all persons using Lot A will first have to walk in a southerly direction away from the Courthouse in order to cross Sixth Street at the intersection with Oak. This brings up the serious issue of traffic hazards between the parking lots and the Courthouse.

Traffic hazards

Regardless of where they park in Lots A and B, all pedestrians—including the disabled—will be forced to cross at the intersection of Sixth and Oak to get to the west side of Sixth. This is the only sidewalk that goes from the parking lots to the Courthouse. The sidewalk on the parking lot (east) side of Sixth doesn’t extend beyond the edge of Lot A itself. A metal barrier has been placed there and beyond the end of the sidewalk is a dirt lot.

It’s obvious that there will be a temptation for all pedestrians—disabled and otherwise—to avoid first walking considerable distances away from the Courthouse in order to legally cross the intersection of Sixth and Oak, only to have to double back toward the Courthouse on the opposite side of Sixth. Instead, pedestrians will be tempted to walk across the planting strip surrounding Lot A or exit against traffic at the parking lot entrance on Sixth and then to jaywalk across Sixth Street directly in front of the Police Station. This would be not only illegal, but dangerous as well.


Assuming pedestrians—including the disabled—follow the signs and cross at the intersection of Sixth and Oak, they face a number of serious traffic hazards along the way to the Courthouse. First, there are no stop signs on Oak Avenue, so traffic will be turning onto Sixth Street without having to stop while pedestrians are crossing Sixth. Worse yet, all pedestrians from Lot B will have to cross both Sixth Street and Oak Avenue without traffic on Oak having to stop.

Second, all pedestrians will have to cross two employee parking lot entrances on the west side of Sixth –one at the Police Station and the other at the Courthouse itself. This, too, is something the ADA strongly discourages.

Finally, all pedestrians from both lots—including the disabled—will have to cross Lincoln Avenue, directly behind the Courthouse, without the benefit of any stop signs on Lincoln. Needless to say, this is extremely dangerous given the fact that the Courthouse itself will be generating increased traffic in the area and the public parking lot for the Police Station is adjacent to the intersection of Sixth and Lincoln.

Possible solutions

I don’t want to point out problems without offering some possible solutions.

Regarding the absence of stop signs on both Oak and Lincoln, the City of Woodland should consider adding them immediately, along with painted pedestrian crosswalks at both intersections.

In order to significantly shorten the distance that disabled persons must travel from parking lot to Courthouse, immediate consideration should be given to relocating the required disabled parking to one of the following locations: (1) Part of the lawn area directly in front of the Courthouse; (2) Renting space in the parking lot at the Wiseman Building across from the Courthouse; or (3) Rent/borrow excess space available in the parking lot of the Woodland District Office of Education building also across from the Courthouse.


The impetus for the investigation that has led to this letter was information unveiled at the Woodland City Council meeting on July 7, 2015, when it passed an ordinance establishing a Preferential Parking Area in the vicinity of the new Courthouse. This was a perfectly understandable effort by the City to preserve on-street parking for residents and businesses in the area from encroachment by visitors to the Courthouse.

In preparation for the Council hearing, a map was presented showing the two remote public parking lots, as well as restricted on-street parking surrounding the Courthouse. Most of this restricted parking is set aside for public safety vehicles and certain County officials. Despite the preparations that were being made for preferential, non-public parking near the Courthouse, it was apparent that no one at the City of Woodland level was giving serious thought to parking needs of the disabled. While it was probably never the City’s responsibility in the first place, in response to questions by Council members City staff wrote off the problem by noting that vehicles with disabled parking placards and license plates are allowed to park almost anywhere on city streets or at meters without restriction, including time limits. While it wasn’t mentioned at the hearing, the law also allows disabled vehicles to park without restriction within the newly established Preferential Parking Area. The only places where disabled vehicles cannot park is in white and yellow loading zones and in red no parking zones.

This somewhat unsatisfactory discussion of disabled parking issues led us to begin inquiring just what serious provisions were being made for ADA-compliant disabled parking. The first thing we learned is that the Judicial Council of California is responsible for construction of the Courthouse, purchase and construction of the parking lots and adherence to the ADA. However. Since the City is responsible for traffic and parking on city streets and Yolo County has assumed responsibility for issuing parking permits within the Preferential Parking Area, this letter is being sent to individuals at all levels of responsibility for the new Courthouse.

The ADA celebrated its 25th anniversary just last month and there is no denying the positive benefits it has had in bringing disabled persons into greater participation in public life. Those responsible for our new Courthouse need to seriously reconsider and correct some of the impediments that are


now apparent. I would appreciate being kept informed of progress along these lines.


Bobby Harris

cc: Martin Hoshino

Administrative Director, Judicial Council of California

Honorable Kathleen M. White

Presiding Judge, Yolo County Superior Court

Shawn C. Landry

Court Executive Officer, Yolo County Superior Court

Matt Rexroad

Chairman, Yolo County Board of Supervisors

Patrick S. Blacklock

County Administrator, Yolo County

Tom Stallard

Mayor, City of Woodland

Paul Navazio

City Manager, City of Woodland



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