The newly proposed Prudler project involves a prime and uniquely urbanizable parcel of 38 acres, bounded by the County Fair Mall and Woodland Community & Senior Center, within the City’s East Street Corridor, a fundamental element of enhancing municipal urbanization.

“The previous [Planning Commission] petition [for this project] submitted on August 5, 2005, from K Hovanian Homes,” describes a relevant letter by (then) community development director, Nick Ponticello, “was specifically designed as an active senior housing development [containing 246 dwelling units]. If the revised project is not in substantial compliance with the previously approved petition, then a new petition is required to be submitted and reviewed by the Planning Commission.”

Ponticello’s letter (Nov. 4, 2011) to Prudler project proponents refers to formal City policy adopted by Woodland City Council, regarding General Plan amendments (Resolution No. 4516-B – February 17, 2004), “outlining a process to allow initial consideration of an amendment to the General Plan.”

Prudler project proponents have ignored this clear direction by Ponticello, predicated on basic city policy, for unknown reasons; such reasons should be made public within the consideration process for this project. A subsequent petition would have required that Prudler project proponents present a new developmental “narrative” and “justification as to why and how a change in the approved General Plan would provide benefit to the community.”

Reasonable folk may easily view the newly proposed Prudler project (189 conventional, low density housing units), identical to much of the Spring Lake Specific Plan (an immense, adjacent, already approved and crucially underperforming project, whose adverse financial condition drains $2 million annually from the city’s Measure E budget), as wholly unnecessary and totally at odds with current city goals and vulnerabilities. Doesn’t the city already have enough Spring Lake, etc.?

Despite any argument that city planning process will serve to correct whatever problems may arise from project proponents’ eschewing of straightforward city policy, the intended value of submitting their revised concept for “initial consideration” in a setting of de novo review, has now been lost; the CEQA process is here underway, absent such supposedly beneficial (“required”) process. Why have such a city policy, if it may be (perhaps unreasonably) disregarded? Do not the project proponents desire to prudently receive initial approval of their new, altogether altered developmental concept, prior to engaging in CEQA process?

A significant environmental effect of the Prudler project (as presently proposed) is delayed / circumvented responsibility for, and satisfaction of, consequences of key land-use imperatives recognized and adopted by Woodland’s voters in 2006, by means of an Urban Limit Line Ordinance (ULLO). The ULLO set a maximum legal perimeter on the size of Woodland, partially purposed with promoting local housing “diversity.” To make reasonable and feasible this provision, the ULLO demands a two-tier strategy toward emphasizing and determining “the potential for increased residential densities / higher density residential uses.”

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

The Prudler project is all three developmental categories noted by the ULLO: “infill,” “undeveloped land,” and an “existing non-residential zoning [  ] conversion.” “[C]ontinually reevaluate” indicates that such specific review clearly will occur upon pivotal planning occasions, such as consideration of the Prudler project.

Consequent to the city ignoring the ULLO in approving the Prudler project, located on a prime and uniquely urbanizable parcel (a keystone location for municipal urbanization) would be unavoidable, unwise and unlawful shifting of obvious burdens and responsibilities involved with the ULLO, to other / future land-use development scenarios.

In order to manifest the ULLO process regarding the Prudler project, the required California Environmental Quality Act (CEQA) Environmental Impact Report for this project must include and properly analyze a “range of reasonable alternatives” (CEQA Guidelines, Section 15126.6). Circumstances related to the ULLO make plain that “the potential for increased residential densities / higher density residential uses” must be reasonably reflected within this CEQA “range of [  ] alternatives.”