[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.