Podzol can generate even if there is a air gap to the dirt and also if there is another dirt block above it.
Steps to create:
make a 3 block tall pillar of dirt
remove the bottom dirt block from the pillar
from the pillar skip 1 block in any direction and plant spruce saplings in a 2x2 space
bonemeal saplings to grow 2x2 spruce tree
podzol will generate on the 2nd dirt block even though there is a air gap and another dirt block ontop
Confirmed in 1.21.70.22 Preview. Requesting ownership as the original reporter went inactive since 2020.