(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