Consider adopting Resolution 2024-11, approving the PIRMI and Sports Park Reorganization to the City of Woodland (annexation to the City and concurrent detachment from the Springlake Fire Protection District) and determining no further environmental review is needed under the California Environmental Quality Act (CEQA) (LAFCo No. 24-01)

The City of Woodland initiated this proposal via City resolution and submitted an application to Yolo LAFCo for processing and consideration. Government Code Section 56375 provides LAFCo with the power to review and approve proposals for "changes in organization" consistent with policies adopted by the Commission. Government Code Section 56021 defines "changes of organization" to include annexation to a city and detaching from a special district, among other actions. The City of Woodland approved a tax sharing agreement (Agreement No. 23-01) with the Yolo County Board of Supervisors (Agreement No. 22-251) filed on February 1, 2023. The subject territory is included within the Sphere of Influence for the City of Woodland as approved by Yolo LAFCo in December 2018 to match the City's Urban Limit Line (ULL) previously approved by its voters. The City of Woodland approved pre-zoning for the subject territory consistent with its 2035 General Plan on November 7, 2023.

The subject territory consists of approximately 128+/- acres total comprised of two areas: (1) the PIRMI industrial area located in the north periphery of the City of Woodland on the NW corner of Kentucky Ave and N East Street; and (2) the Sports Park parcel located in the south periphery of the City immediately east of (or behind) the Woodland Community and Senior Center. The territory is currently zoned by the County as Heavy Industrial and Agricultural Intensive. Both areas are within the City's Sphere of Influence (SOI). The proposed reorganization includes: (1) annexation to the City of Woodland; and (2) concurrent detachment from the Springlake Fire Protection District (FPD). The Springlake FPD contracts with the City of Woodland for fire protection services already, and the current service agreement passes through all its revenue to the City for services. Therefore, although the reorganization will change the path by which the City receives this fire protection funding, the City provides fire services either way. 

Factors to be Considered

In accordance with Government Code Section 56668, the factors to be considered in the review of a proposal shall include, but is not limited to, all of the following:

Yolo LAFCo's local standards of evaluation for proposals (Section 2.0) elaborates on these state-mandated factors with the following additional standards:

The proposed annexation area is within the City's sphere of influence (SOI) and is a logical and orderly extension of the City’s urban area. The annexation areas either already have City services/utilities or will need them, and the City has the capacity and is the appropriate agency to provide services. The subject territory is mostly surrounded by existing city jurisdiction and the proposal does not create any "islands" or corridors of unincorporated territory. Both annexation areas are not identified for growth in the June 2024 Land Use Assumptions adopted by SACOG for the regional transportation plan. However, both areas are already mostly developed and are consistent with the City's 2035 General Plan land use designations. The City of Woodland has pre-zoned the PIRMI area as Industrial (I)/Light Industrial Flex Overlay (IF) and Pubic/Quasi-Public (PQP) with Light Industrial Flex Overlay (IF) with one 8.75-acre parcel designated as Flood Study Area (FSA). The Sports Park parcel is prezoned Public/Quasi Public (PQP) consistent with its General Plan and the existing surrounding uses.

The PIRMI area is already developed with industrial uses, and the annexation area is disturbed with no agricultural land remaining. The Sports Park parcel is partially developed (approximately 1/3rd) with sports fields and the rear portion is undeveloped with agricultural uses (approximately 20 acres of Prime Farmland). However, the City exempts public facilities from agricultural mitigation requirements (and the County's mitigation ordinance does as well).  Yolo LAFCo Project Policy 4.13 provides “that, in the case of proposals that are undertaken exclusively for the benefit of a public agency, the Commission should review the applicability of the mitigation requirements set forth in this Policy on a case-by-case basis to determine the appropriateness of requiring mitigation in any particular case.” Staff recommends mitigation not be required for this portion of the Sports Park parcel because the City does not have a practical option to locate elsewhere, impacts are not growth inducing, a Statement of Overriding Considerations has already been adopted for this impact, the City does not have additional funding to mitigate this impact which would reduce public facilities, and the public good is served by the Sports Park project. Therefore, staff recommends the proposal is consistent with Yolo LAFCo's Agricultural Conservation Policy.

The City's 2035 General Plan and CAP EIR analyzed the capacity and availability of public services and utilities and concluded that the City has the capacity to serve the project. Because the territory will be zoned Industrial and Public/Quasi Public, it will not affect the City in achieving its regional housing needs. The proposal boundary does not exclude any existing communities that should be provided equal access to municipal services. The subject area is not identified as a "very high fire hazard zone". The City and County have approved a property tax exchange agreement. For all these reasons, staff recommends that the annexation proposal complies with required state factors and local standards of evaluation. There are 12 parcels affected in the PIRMI (Pacific International Rice Mills) area which do not have 100% landowner participation and 1 Sports Park parcel owned by the City (13 total). Therefore, LAFCo approval of the proposed reorganization is subject to Protest Proceedings and the protest hearing will be scheduled for the October 31, 2024, LAFCo meeting. 

Agency and Public Comments
The project was routed to all subject, affected, and interested agencies on July 22, 2024. No issues or objections have been received from any affected or interested agency. Public notices were mailed to all landowners and registered voters within 300 feet, and published in the Woodland Daily Democrat on September 4, 2024. Staff received a telephone call from the property owner of 1000 Kentucky Ave. with questions about the proposal, but he was not concerned about the annexation. Staff received another phone message, but has not connected with the caller yet.

CEQA

The Woodland City Council approved pre-zoning for the subject territory on November 7, 2023, and determined the Project was not subject to further CEQA environmental review pursuant to Guidelines Section 15183. Yolo LAFCo’s CEQA review as a Responsible Agency is more limited than a Lead Agency. Pursuant to CEQA Guidelines Section 15096, Yolo LAFCo has considered the determination by the City of Woodland and has determined that it is acceptable and legally adequate for use by Yolo LAFCo. The proposed annexations are consistent with the development type and density established by existing land use designations under the City of Woodland General Plan policies for which an EIR was certified in 2017 (“2035 General Plan and CAP EIR”).

When Yolo LAFCo prepared a Municipal Service Review and expanded the City’s Sphere of Influence to match the Urban Limit Line (ULL), LAFCo disclosed that future annexation would result in the loss of prime agricultural land. The City’s 2035 General Plan EIR mitigates this loss consistent with LAFCo policies and LAFCo concluded that this loss was significant and unavoidable (Yolo LAFCo Resolution No. 2018-10 adopted on January 24, 2019). Annexation does not result in any additional impacts that were not already disclosed.

No new significant impacts specifically related to the proposed annexations or annexation areas are anticipated that were not otherwise identified under the 2035 General Plan and CAP EIR. There would not be potentially significant off-site and/or cumulative impacts that the 2035 General Plan and CAP EIR failed to evaluate. There is no substantial new information that would result in more severe impacts than anticipated by the 2035 General Plan and CAP EIR.

The proposed annexations would be subject to uniformly applied policies, regulations, and development standards that implement the 2035 General Plan, as applicable to any future development located within the annexation areas. Where the 2035 General Plan includes policies and implementation programs developed for the purposes of minimizing and avoiding environmental impacts and that would not be otherwise enforced through existing regulations, the City would enforce implementation of such policies and implementation programs through Conditions of Approval. Therefore, no further review is required for the project pursuant to CEQA Guidelines Section 15183.