[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.