YOLO SUN OPINION :

[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) —

http://www.cityofwoodland.org/civicax/filebank/blobdload.aspx?blobid=13682

*  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) :

http://www.cityofwoodland.org/civicax/filebank/blobdload.aspx?blobid=15244

*  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

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