Attachment B_Screening_Analysis_Staff_Recommendations

Special City Council Meeting, January 22, 2026 · item 4B: Consideration of a motion to approve the list of community change requests to be considered during the Boulder Valley Comprehensive Plan upd… · 77 pages

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Request #1 Address: Request Type: Current Land Use: Proposed Land Use: Staff Recommendation:

1343 Iris Avenue Land Use Map Change Public (PUB) High Density Residential (HR); or Medium Density Residential (MR); or Low Density Residential (LR) Yes, consider further under the new draft Future Land Use Map

Applicant Narrative: Boulder County is requesting a Land Use change for the County-owned property at 1333 Iris Avenue, on the northeast corner of the intersection of Broadway and Iris in North Boulder (North Broadway Complex). The County is suggesting a change from its current use designation, Public (P), to Residential (R) without specified zoning. This property is 17.5 acres including parking lots, 5 office buildings, a playground, paths and open field space. The County believes this property is ripe for residential use for three reasons: supporting space for housing needs by increasing supply for a growing front-range population, existing infrastructure for transportation and accessibility, and alignment with strategy and vision for the region. There’s been no more pressing conversation across Colorado (and Boulder County) than the need for housing. The Denver metro region “needs to build 511,000 units by 2050 to meet current and future housing needs” according to a June 2024 Regional Housing Needs Assessment produced by the Denver Regional Council of Governments (DRCOG.) This property, 17.5 contiguous acres within City limits on transit routes and with existing utilities to the site, offers significant opportunity to increase supply. While the County is not submitting a zoning preference for the property, this campus represents an opportunity for in-fill meeting affordable or attainable inventory needs including the possibility of units suitable for ownership or rent to own. Housing in Boulder County (and, more specifically, the City of Boulder) remains amongst the most expensive in the State of Colorado and the United States overall. The Boulder County Community Foundation’s Trends Report finds that the average median home value for Boulder County now tops $713,000 and is substantially higher in the City of Boulder. Ownership seems increasingly out of reach and is likely to pressure existing residents, the local economy and the viability of local employment and educational entities. One misconception in the affordable housing space is that affordable homes need to be single family style homes with a large yard. This location, on existing transit routes just north of downtown, is an opportunity to explore affordable or attainable ownership housing solutions for the community in other formats: potentially mixed use residential in a walkable area for families of all types who desire a potentially smaller footprint or shared amenities and greenspace. There is a wealth of knowledge in the housing space in the City and County of Boulder in government organizations, non-profit partners and the development community. Boulder County hopes organizations leverage these partnerships to explore the needs of the community. 1

This location on the Iris and Broadway corridor has the conditions to create a walkable and transit accessible neighborhood. There are two lines of existing transit, including RTD Skip and LF lines5, as well as two walking paths, Iris Path and Broadway Path. In addition, utilities exist to the site. Roughly 30% of the property appears to be in the 500 year flood plane, and less than 10% of the property appears to be in the 100 year flood plane. The flood appears to come from the Western property edge and then flow southeast to Iris Avenue. This proposal for land use change would allow a potential purchaser’s vision for residential development to continue exploration of highest/best use of the property in alignment with this comprehensive plan update and with City of Boulder permitting requirements. Changing the land use for the North Broadway property aligns with long-term, comprehensive strategy of the region. It also aligns with recent feedback received by the community during this Comprehensive Plan Update process which focuses on the creation and enhancement of walkable neighborhoods. The Regional Housing Collaborative, Boulder County Housing Authority, and The City of Boulder have acknowledged the need for affordable low-, moderate-, and middle-income households; affordable is typically defined as household spending less than 30% of their income on housing. The Boulder County Regional Housing Plan in part calls for "securing land and development/redevelopment opportunities” which appear to align with the opportunity presented in shifting the land use of the North Broadway Complex property. Goals set by the Boulder County Regional Housing Partnership seek strategies for achieving the 12% regional affordable units goal which may leverage this property. One of the primary challenges to affordable housing is the high demand, with limited space available for new homes. While the ability and capacity of the local housing development market remains challenged by rising costs of land and construction, recent state and local legislation continue to pursue opportunities to address Boulder County housing needs (re: condo defect-related legislation, density considerations, etc).

Screening Analysis: CRITERIA #1 – CONSISTENCY WITH COMPREHENSIVE PLAN GOALS Accessible & Connected, Economically Vital, Environmentally Sustainable, Healthy and Socially Thriving, Livable, Responsibly Governed, Safe

Yes

CRITERIA #2 – WITHIN THE POLICY LEVEL SCOPE OF THE COMPREHENSIVE PLAN

Yes

Is the request within the policy level scope of the Comprehensive Plan?

CRITERIA #3 – CAPACITY FOR TIMELY ANALYSIS Can the scope of the impact of the potential change be accommodated within the Comprehensive Plan update process and timeline?

Yes

CRITERIA #4 – CONSISTENCY WITH PROPOSED PLAN DIRECTION Is the request consistent with the latest Comprehensive Plan policy and new draft Future Land Use Map direction?

Yes

X 2

Staff Recommendation: Yes, consider further under the new draft Future Land Use Map Staff recommends further consideration of this request within the context of the new draft Future Land Use Map. Although the High Density Residential (HR), Medium Density Residential (MR) and Low Density Residential (LR) land use designations will be consolidated through the Comprehensive Plan update, the request reflects the intent to introduce residential development on the County-owned property to help address regional housing needs. The property is well-served by existing transit, infrastructure, and nearby services, supporting efficient, compact development. This request is generally consistent with draft Comprehensive Plan policy and Future Land Use Map direction.

Request #2 Address: Request Type: Current Land Use: Proposed Land Use: Staff Recommendation:

4655 Table Mesa Drive Land Use Map Change Low Density Residential (LR) High Density Residential (HR) Yes, consider further under the new draft Future Land Use Map

Applicant Narrative: This underutilized RTD PnR would have far greater potential to serve the Boulder community if it was zoned High Density Residential. HDR zoning would be consistent with adjacent properties to the east that also have the high density (HR) land use, and, at 1.25 acres, the property is far too large for low density residential. Additionally, the site is extremely well served by transit with the flatiron flyer, DASH, 204, 206, and AB directly in front of the property. Thanks to its excellent transit connections, DOLA recognized the area as potential TOD in its HB-1313 TOC legislation maps. As Boulder responds to state requirements and meets its own needs and goals, this site is an excellent location for high density multifamily development, and also has strong potential for affordable housing, which would support RTD's Equitable TOD Policy. Lastly, with RTD as the landowner, any potential development at this site would be contemplated in coordination with the City of Boulder and local stakeholders to ensure it met local priorities and needs.

Yes

CRITERIA #2 – WITHIN THE POLICY LEVEL SCOPE OF THE COMPREHENSIVE PLAN

Yes

Is the request within the policy level scope of the Comprehensive Plan?

X No

CRITERIA #3 – CAPACITY FOR TIMELY ANALYSIS Can the scope of the impact of the potential change be accommodated within the Comprehensive Plan update process and timeline?

Yes

CRITERIA #4 – CONSISTENCY WITH PROPOSED PLAN DIRECTION Is the request consistent with the latest Comprehensive Plan policy and new draft Future Land Use Map direction?

Yes

X No

Staff Recommendation: Yes, consider further under the new draft Future Land Use Map Staff recommends further consideration of this request within the context of the new draft Future Land Use Map. Although the High Density Residential (HR) land use designation will be consolidated through the Comprehensive Plan update, the request reflects the intent to introduce additional residential development on an underutilized site to support housing and transit-oriented development goals. The property is well-served by existing transit, infrastructure, and nearby services, supporting efficient, compact development. This request is generally consistent with draft Comprehensive Plan policy and Future Land Use Map direction.

Request #3 Address: Request Type: Current Land Use: Proposed Land Use: Staff Recommendation:

2750 Broadway Land Use Map Change Transitional Business (TB) Community Business (CB) Yes, consider further under the new draft Future Land Use Map

Applicant Narrative: Boulder Medical Center has existed in its current location for over 75 years. However it is highly likely that Boulder Medical Center pre-dates the establishment of any Land Use Designation being applied to its property. The history of when and how Land Use Designations first came into being in the city is not available, so we can’t be certain of how the Transitional Business (TB) designation came to be attached to the site. Anecdotally… In raising this point with the Planning Director, he said it would be reasonable to think that when the first Land Use Map for the city was created, someone drove by and said, well, it’s a medical center so let’s support that activity in the Land Use Map designation. Hence the Transitional Business designation. In that time, the medical use and the use designation have had a good and healthy marriage. However, things change. Indeed the Center needs significant improvements to be a state of the art medical facility that can provide for the evolving needs of Boulder. This cannot be done in the current location for many reasons – most significantly because the Medical Center is a designated Critical Facility. The structure sits within both the 500 year and the 100 year Floodplain Boundaries; much of it is ±9’ below the Flood Protection Elevation required for the structure. Therefore floodproofing would be required if the center were to make the needed upgrades. Doing so – while also maintaining its operations – is not feasible. Consequently, the Medical Center will have to relocate to a new site where such improvements can be accomplished. MEDICAL CENTER’S DEPARTURE FROM 2750 BROADWAY The current land use designation does not make sense for the property once the medical use is no longer the site’s predominant activity. Upon the Center’s departure the most appropriate future land use the property is Community Business (CB), the same designation as the remainder of the block, shared today with IDEAL BROADWAY SHOPS. This designation would allow for the full block of the neighborhood center designation to the south to be applied to this highly accessible site. Once the site is cleared, it would be then possible to build a new facility meeting the city’s floodplain regulations and eventually making it possible to provide high density housing directly adjacent to neighborhood shops and activity. And like the adjacent neighborhood center itself, the 6

Community Business designation would lead to a rezoning of the property to BC-2 where housing associated with Neighborhood Centers is encouraged. The city has a need for housing in this location, and the opportunity to maximize its potential on this site is greatly enhanced with the change proposed. IDEAL BROADWAY SHOPS and the adjacent COMMUNITY PLAZA both have BC-2 zoning and are identified by Land Use Code Appendix N for Special Use Restrictions. But sites are constricted by floodplain regulations and likely landmarking limitations. Therefore this BMC site provides an opportunity to provide higher density housing adjacent to the Neighborhood Center that is not otherwise easily achievable. MEDICAL CENTER’S RELOCATION New medical facilities are expensive to build; land sufficient to support a medical center’s needs are difficult to find in Boulder – i.e. expensive. The medical center’s most significant tangible asset to provide for that upgrade is the land that it sits on today. Consequently, the funds raised from the sale of their existing land has to substantially provide for their new facility in Boulder. To better serve their existing clients, this would at best be somewhere near their current location, where land costs are extremely high. Allowing for high density housing as a part of the Neighborhood Center would provide the most support for the financial needs of the Medical Center and significantly enhance its ability to provide for the needs of the Boulder Community for decades to come. BVCP POLICIES IN SUPPORT OF MAP CHANGE This request reflects changes to the physical conditions, supports the goals of the Plan &: • Is on balance consistent with the policies & intent of the Plan; • Has no cross-jurisdictional impacts outside of the city; • Would not affect the growth projection basis of the Plan; • Would not affect the provision of urban services to the area; & • Does not affect the city’s Capital Improvements Program. Principal 2015 BVCP policy supporting this request: 8.13 Support for Community Facilities The city and county recognize the importance of educational, health, cultural and non-profit community agencies that provide vital services to the residents of the Boulder Valley and will work collaboratively with these agencies to reasonably accommodate their facility needs and consider location based on transportation accessibility or other needs. Also: 3.22 Floodplain Management 7.10 Housing for a Full Range of Households 7.11 Balancing Housing Supply with Employment Base

Yes

X 7

CRITERIA #2 – WITHIN THE POLICY LEVEL SCOPE OF THE COMPREHENSIVE PLAN

Yes

Is the request within the policy level scope of the Comprehensive Plan?

CRITERIA #3 – CAPACITY FOR TIMELY ANALYSIS Can the scope of the impact of the potential change be accommodated within the Comprehensive Plan update process and timeline?

Yes

CRITERIA #4 – CONSISTENCY WITH PROPOSED PLAN DIRECTION Is the request consistent with the latest Comprehensive Plan policy and new draft Future Land Use Map direction?

Yes

X No

Staff Recommendation: Yes, consider further under the new draft Future Land Use Map Staff recommends further consideration of this request within the context of the new draft Future Land Use Map. Although the Community Business (CB) land use designation will be consolidated through the Comprehensive Plan update, the request reflects the intent to introduce a designation that supports future redevelopment of the site, including potential high-density housing adjacent to the neighborhood center, once the existing medical use relocates. The property is well-served by existing transit, infrastructure, and nearby services, supporting efficient, compact development. This request is generally consistent with draft Comprehensive Plan policy and Future Land Use Map direction.

Request #4 Address: Request Type: Current Land Use: Proposed Land Use: Staff Recommendation:

2425 Colorado Avenue Land Use Map Change Low Density Residential (LR) High Density Residential (HR) Yes, consider further under the new draft Future Land Use Map

Applicant Narrative: This request is to change the land use designation for the St. Aidan’s properties at 2425 Colorado Ave to allow greater flexibility and accommodate high density housing alongside its long-standing role as a faith-based community institution. St. Aidan’s is uniquely located across from the University of Colorado Boulder campus, near transit, services, and employment centers. Its central location makes it well-suited to provide community-serving housing that supports Boulder’s broader goals of equity, affordability, and sustainability. The land use change would allow for thoughtfully designed residential development on the property that could deliver housing opportunities for low- and middle-income households, including students, staff, young families, and essential workers. These populations are increasingly priced out of Boulder’s housing market, and creating affordable options near campus and transit will directly advance BVCP policies promoting inclusivity, community diversity, and equitable access to opportunity. Allowing additional density on the St. Aidan’s property also represents a more efficient use of centrally located, underutilized land. Many faith-based and non-profit properties like St. Aidan’s have excess land area or facilities that no longer match contemporary needs. Updating the land use designation to enable residential development, in partnership with community-serving organizations, ensures these assets contribute to the greater public good while preserving the long-term mission and presence of the institution. This change also strengthens the financial sustainability of St. Aidan’s. By allowing for compatible residential development, the congregation can create new pathways to maintain and invest in its facilities while continuing to provide worship, gathering, and outreach services that benefit the broader community. In this way, the land use change not only addresses Boulder’s housing shortage but also safeguards the ongoing role of a valued community institution. From a sustainability perspective, adding housing on the St. Aidan’s property reduces the pressure for sprawl and supports climate goals by placing residents in a walkable, bikeable, and transit-served location. It integrates housing with existing infrastructure rather than expanding the city’s footprint. 9

In summary, this land use designation change for the St. Aidan’s property advances multiple BVCP priorities: --Housing Affordability and Choice: Creates opportunities for low- and middle-income households who are increasingly excluded from Boulder. --Equity and Inclusion: Provides access to housing for students, workers, and families near services and employment. --Sustainability: Promotes compact, efficient development in a central location with strong transit access. --Community-Serving Institutions: Helps preserve in our location of ministry the presence and mission of St. Aidan’s while unlocking new community benefits. St. Aidan’s is ready to serve as a partner in addressing Boulder’s most pressing housing challenges. With a land use designation that reflects this potential, the property can both continue its faith-based mission and contribute significantly to the city’s goals for a more affordable, equitable, and sustainable future.

Yes

CRITERIA #2 – WITHIN THE POLICY LEVEL SCOPE OF THE COMPREHENSIVE PLAN

Yes

Is the request within the policy level scope of the Comprehensive Plan?

CRITERIA #3 – CAPACITY FOR TIMELY ANALYSIS Can the scope of the impact of the potential change be accommodated within the Comprehensive Plan update process and timeline?

Yes

CRITERIA #4 – CONSISTENCY WITH PROPOSED PLAN DIRECTION Is the request consistent with the latest Comprehensive Plan policy and new draft Future Land Use Map direction?

Yes

X No

Staff Recommendation: Yes, consider further under the new draft Future Land Use Map Staff recommends further consideration of this request within the context of the new draft Future Land Use Map. Although the High Density Residential (HR) land use designation will be consolidated through the Comprehensive Plan update, the request reflects the intent to introduce additional residential development while retaining St. Aidan’s long-standing role as a faith-based community institution. The property is well-served by existing transit, infrastructure, and nearby services, supporting efficient, compact development. This request is generally consistent with draft Comprehensive Plan policy and Future Land Use Map direction.

Request #5 Address: Request Type: Current Land Use: Proposed Land Use: Staff Recommendation:

2419 Colorado Avenue Land Use Map Change Low Density Residential (LR) High Density Residential (HR) Yes, consider further under the new draft Future Land Use Map

Applicant Narrative: This request is to change the land use designation for the St. Aidan’s properties at 2419 Colorado Ave to allow greater flexibility and accommodate high density housing alongside its long-standing role as a faith-based community institution. St. Aidan’s is uniquely located across from the University of Colorado Boulder campus, near transit, services, and employment centers. Its central location makes it well-suited to provide community-serving housing that supports Boulder’s broader goals of equity, affordability, and sustainability. The land use change would allow for thoughtfully designed residential development on the property that could deliver housing opportunities for low- and middle-income households, including students, staff, young families, and essential workers. These populations are increasingly priced out of Boulder’s housing market, and creating affordable options near campus and transit will directly advance BVCP policies promoting inclusivity, community diversity, and equitable access to opportunity. Allowing additional density on the St. Aidan’s property also represents a more efficient use of centrally located, underutilized land. Many faith-based and non-profit properties like St. Aidan’s have excess land area or facilities that no longer match contemporary needs. Updating the land use designation to enable residential development, in partnership with community-serving organizations, ensures these assets contribute to the greater public good while preserving the long-term mission and presence of the institution. This change also strengthens the financial sustainability of St. Aidan’s. By allowing for compatible residential development, the congregation can create new pathways to maintain and invest in its facilities while continuing to provide worship, gathering, and outreach services that benefit the broader community. In this way, the land use change not only addresses Boulder’s housing shortage but also safeguards the ongoing role of a valued community institution. From a sustainability perspective, adding housing on the St. Aidan’s property reduces the pressure for sprawl and supports climate goals by placing residents in a walkable, bikeable, and transit-served location. It integrates housing with existing infrastructure rather than expanding the city’s footprint. 11

Yes

CRITERIA #2 – WITHIN THE POLICY LEVEL SCOPE OF THE COMPREHENSIVE PLAN

Yes

Is the request within the policy level scope of the Comprehensive Plan?

CRITERIA #3 – CAPACITY FOR TIMELY ANALYSIS Can the scope of the impact of the potential change be accommodated within the Comprehensive Plan update process and timeline?

Yes

CRITERIA #4 – CONSISTENCY WITH PROPOSED PLAN DIRECTION Is the request consistent with the latest Comprehensive Plan policy and new draft Future Land Use Map direction?

Yes

X No

Staff Recommendation: Yes, consider further under the new draft Future Land Use Map Staff recommends further consideration of this request within the context of the new draft Future Land Use Map. Although the High Density Residential (HR) land use designation will be consolidated through the Comprehensive Plan update, the request reflects the intent to introduce higher-density residential development while retaining St. Aidan’s long-standing role as a faith-based community institution. The property is wellserved by existing transit, infrastructure, and nearby services, supporting efficient, compact development. This request is generally consistent with draft Comprehensive Plan policy and Future Land Use Map direction.

Request #6 Address: Request Type: Current Land Use: Proposed Land Use: Staff Recommendation:

2851 Valmont Road Land Use Map Change Medium Density Residential (MR) Mixed-Use Business (MUB) Yes, consider further under the new draft Future Land Use Map

Applicant Narrative: We are requesting a Land Use Designation from MR to MUB, per the 2020 Boulder Valley Comp Plan (the “Comp Plan”) for our property located at 2851 Valmont Road. The property is currently zoned RM-1 and was originally a single-family residence that included out-buildings. At that time, in the 1970’s and 1980’s, this area was more rural in character with lower density. For the past 35 years, the property was occupied by Sturtz & Copeland Florist & Greenhouse (our family business) up until the business was sold and relocated in 2023. Over the years, the growth and expansion of Boulder has bypassed the property with development that includes medium and high density residential, commercial and retail uses. The physical condition of the area has also changed, and Valmont Road is now better served by the transportation and infrastructure developed by the City for cars, bikes and pedestrian traffic. The infrastructure supports density and a mix of uses as Valmont now functions as an east/west connector from 55th Street to Folsom Street. The change of use will also allow future development that is more consistent with The City of Boulder future planning efforts as well as the Comp Plan. Below are some examples and sections from the Comp Plan and the shared Community Goals that support our request: Comp Plan Core Values: • To create compact, contiguous development and infill that supports evolution to a more sustainable urban form; • Neighborhood connectivity should align with the all-mode transportation system to make getting around without a car easy and accessible to everyone Section 2- Built Environment. Encourage more sustainable Urban Form development that is compact with density in locations guided by the Land Use Map to create and support a variety of housing types, viable commercial opportunities and high frequency public transit. Allow for daily needs to be met within easy access from home, work, school, services or recreation without driving a car. MUB is consistent with this approach. Section 2.14- Mix of Complementary Land Uses, the city and county will strongly encourage, consistent with other land use policies, a variety of land uses in new developments. In existing neighborhoods, a mix of land use types, housing sizes and lot sizes may be possible if properly mitigated and respectful of neighborhood character. MUB is consistent with this approach. 13

Section 2.15 Compatibility of Adjacent Land Uses, the immediate area, especially along Valmont and 28th Street, consists of several COB zoning designations that are consistent with the MUB use. Section 2.18 Boulder Valley Regional Center & 28th Street, the city will preserve and enhance the BVRC as a high-intensity regional commercial center while encouraging the addition of a variety of housing types. MUB is consistent with this approach. Community Goals: The Community Goals as stated below to help prioritize choices about the Boulder Valley’s Future also align with our request for change of use to MUB: • Accessible & Connected • Environmentally Sustainable • Economically Vital • Livable • Safe We believe the MR use designation and RM-1 zoning along our section of Valmont is no longer viable, nor is it consistent with the Comp Plan, Community Goals, and City Planning. The change of use to MUB will allow future development to be more responsive to today’s needs within the City of Boulder and our specific neighborhood. Thank you for your consideration.

Yes

CRITERIA #2 – WITHIN THE POLICY LEVEL SCOPE OF THE COMPREHENSIVE PLAN

Yes

Is the request within the policy level scope of the Comprehensive Plan?

CRITERIA #3 – CAPACITY FOR TIMELY ANALYSIS Can the scope of the impact of the potential change be accommodated within the Comprehensive Plan update process and timeline?

Yes

CRITERIA #4 – CONSISTENCY WITH PROPOSED PLAN DIRECTION Is the request consistent with the latest Comprehensive Plan policy and new draft Future Land Use Map direction?

Yes

X No

Staff Recommendation: Yes, consider further under the new draft Future Land Use Map Staff recommends further consideration of this request within the context of the new draft Future Land Use Map. Although the Mixed Use Business (MUB) land use designation will be consolidated through the Comprehensive Plan update, the request reflects the intent to introduce a designation that allows a mix of residential and commercial uses consistent with surrounding development along Valmont Road. The property is well-served by existing transit, infrastructure, and nearby services, supporting efficient, compact development. This request is generally consistent with draft Comprehensive Plan policy and Future Land Use Map direction.

Request #7 Address: Request Type: Current Land Use: Proposed Land Use: Staff Recommendation:

0 Twin Lakes Road. Land Use Map Change Public (PUB) Open Space- Acquired (OS-A) No, do not consider further under the new draft Future Land Use Map

Applicant Narrative: In concert with 6655 Twin Lakes Road and 0 Kahlua Road, the property qualifies for open space according to the County’s acquisition criteria. Parks and Open Space staff strive to acquire land that meets these criteria: - Land threatened by development that is near or adjacent to existing open space - Prime agricultural land -Wildlife habitat - Riparian and scenic corridors - Land that could provide trail connections. http://www.bouldercounty.org/os/openspace/pages/acquisitions.aspx According to the County description of the existing Open Space: In the 1960s, thanks to the nearby IBM plant and other commercial attractions, the Gunbarrel residential area grew up around the lakes. The lakes have been central to the Gunbarrel community from the beginning. http://www.bouldercounty.org/os/parks/pages/twinlakes.aspx As the community has grown, the need for additional open space to accommodate additional residents has grown with it. So has the need to better protect remaining natural values under siege from encroaching development on private land has grown with it. Now is the time to protect this parcel and expand the existing Open Space. This request is submitted with parallel requests for the adjacent properties at 6655 Twin Lakes Road (9.97 acres), and 0 Kalua Road (6.08 acres), which are located directly south of 6655 Twin Lakes Road. The two southern parcels are currently owned by Boulder Valley School District (the “BVSD parcels”). Thus, including this 3.97-acre 6650 parcel, the County, City, and community have a rare chance to expand Gunbarrel’s magnificent Twin Lakes Open Space by a total of 17 acres. All three proposed properties are currently publicly owned. This unique opportunity for the 2015 BVCP Update is made possible by the County’s purchase of 6655 in 2013, and the fact that BVSD has stated it has no plans to use 6650 or 0 Kahlua for School District purposes. For more details on this Land Use Change Request, see item 1F from the 2015 Comprehensive Plan Update, and items 10-12 from the 2020 Update. 16

Yes

CRITERIA #2 – WITHIN THE POLICY LEVEL SCOPE OF THE COMPREHENSIVE PLAN

Yes

Is the request within the policy level scope of the Comprehensive Plan?

CRITERIA #3 – CAPACITY FOR TIMELY ANALYSIS Can the scope of the impact of the potential change be accommodated within the Comprehensive Plan update process and timeline?

Yes

CRITERIA #4 – CONSISTENCY WITH PROPOSED PLAN DIRECTION Is the request consistent with the latest Comprehensive Plan policy and new draft Future Land Use Map direction?

Yes

Staff Recommendation: No, do not consider further under the new draft Future Land Use Map Staff does not recommend further consideration of this request within the context of the new draft Future Land Use Map. The request is generally inconsistent with the most recent draft policy and land use map direction. The parcel is in Area II (the area designated for urban services) and has been intended for annexation into the city since the 1970s. Urban services (i.e. water, wastewater, stormwater, roads, etc.) are available near the parcel. While the site has clear value to the adjacent neighbors for its scenic quality and other resource values, neither the county nor city has found the site to meet their respective criteria for open space designation or acquisition for broader community benefit.

Request #8 Address: Request Type: Current Land Use: Proposed Land Use: Staff Recommendation:

6655 Twin Lakes Road Land Use Map Change Low Density Residential (LR) Open Space- Acquired (OS-A) No, do not consider further under the new draft Future Land Use Map

Applicant Narrative: The property is ideal for open space according to the County’s acquisition criteria: Parks and Open Space staff strive to acquire land that meets these criteria: • Land threatened by development that is near or adjacent to existing open space • Prime agricultural land • Wildlife habitat • Riparian and scenic corridors • Land that could provide trail connections. http://www.bouldercounty.org/os/openspace/pages/acquisitions.aspx According to the County description of the existing Twin Lakes Open Space: In the 1960s, thanks to the nearby IBM plant and other commercial attractions, the Gunbarrel residential area grew up around the lakes. The lakes have been central to the Gunbarrel community from the beginning. http://www.bouldercounty.org/os/parks/pages/twinlakes.aspx As the community has grown, the need for additional open space to accommodate additional residents has grown with it. So has the need to better protect remaining natural values under siege from encroaching development on private land. Now is the time to protect this parcel and expand the existing Open Space. This request is submitted with parallel requests for the adjacent properties at 6650 Twin Lakes Road (3.95 acres) and 0 Kalua Road (6.08 acres), which are located directly south of 6655 Twin Lakes Road. The two southern parcels are currently owned by Boulder Valley School District (the “BVSD parcels”). Thus, including the 9.97-acre 6655 parcel, the County, City, and community have a rare chance to expand Gunbarrel’s magnificent Twin Lakes Open Space by a total of 17 acres. All three proposed properties are currently publicly owned. See our Land Use Change Requests 1E in the 2015 Comprehensive Plan Update, and items 10-12 in the 2020 Update, for additional details on this request.

Yes

CRITERIA #2 – WITHIN THE POLICY LEVEL SCOPE OF THE COMPREHENSIVE PLAN

Yes

Is the request within the policy level scope of the Comprehensive Plan?

CRITERIA #3 – CAPACITY FOR TIMELY ANALYSIS Can the scope of the impact of the potential change be accommodated within the Comprehensive Plan update process and timeline?

Yes

CRITERIA #4 – CONSISTENCY WITH PROPOSED PLAN DIRECTION Is the request consistent with the latest Comprehensive Plan policy and new draft Future Land Use Map direction?

Yes

No X No

X No X

Request #9 Address: Request Type: Current Land Use: Proposed Land Use: Staff Recommendation:

0 Kalua Road Land Use Map Change Public (PUB) Open Space - Acquired (OS-A) No, do not consider further under the new draft Future Land Use Map

Applicant Narrative: In concert with 6655 Twin Lakes Road and 6650 Twin Lakes Road, the property qualifies for open space according to the County’s acquisition criteria: Parks and Open Space staff strive to acquire land that meet these criteria: • Land threatened by development that is near or adjacent to existing open space • Prime agricultural land • Wildlife habitat • Riparian and scenic corridors • Land that could provide trail connections. http://www.bouldercounty.org/os/openspace/pages/acquisitions.aspx According to the County description of the existing Open Space: In the 1960s, thanks to the nearby IBM plant and other commercial attractions, the Gunbarrel residential area grew up around the lakes. The lakes have been central to the Gunbarrel community from the beginning. http://www.bouldercounty.org/os/parks/pages/twinlakes.aspx As the community has grown, the need for additional open space to accommodate additional residents has grown with it. So has the need to better protect remaining natural values under siege from encroaching development on private land has grown with it. Now is the time to protect this parcel and expand the existing Open Space. This request is submitted with parallel requests for the adjacent properties at 6655 Twin Lakes Road (9.97 acres), and 6650 Twin Lakes Road (3.97 acres), which are located directly south of 6655 Twin Lakes Road. The two southern parcels are currently owned by Boulder Valley School District (the “BVSD parcels”). Thus, including this 6.08-acre 0 Kalua Road parcel, the County, City, and community have a rare chance to expand Gunbarrel’s magnificent Twin Lakes Open Space by a total of 17 acres. For more information on this Land Use Change, please refer to item 1G in the 2015 Comprehensive Plan Update, and items 10-12 in the 2020 Update.

Yes

CRITERIA #2 – WITHIN THE POLICY LEVEL SCOPE OF THE COMPREHENSIVE PLAN

Yes

Is the request within the policy level scope of the Comprehensive Plan?

CRITERIA #3 – CAPACITY FOR TIMELY ANALYSIS Can the scope of the impact of the potential change be accommodated within the Comprehensive Plan update process and timeline?

Yes

CRITERIA #4 – CONSISTENCY WITH PROPOSED PLAN DIRECTION Is the request consistent with the latest Comprehensive Plan policy and new draft Future Land Use Map direction?

Yes

No X No

X No X

Request #10 Address: Request Type: Current Land Use: Proposed Land Use: Staff Recommendation:

Sioux Drive between Pawnee Drive and Thunderbird Drive Land Use Map Change Low Density Residential (LR) Medium Density Residential (MR) Yes, consider further under the new draft Future Land Use Map

Applicant Narrative: Sioux Drive between Pawnee and Thunderbird separates two substantially different land use/zoning designations. The south side of the street has a Low Density Residential land use and the north side is High Density. The south side is zoned RE and the north side is zoned RH-5. This difference in land use and zoning creates two very different urban and suburban forms that are incompatible without some mediating zone or at least a much wider right-ofway. Their juxtaposition across a typical residential street is incongruous. I propose changing the lots on the south side of Sioux Drive to medium density residential land use and RM-1 zoning. Here is my rationale: Existing Condition: Frasier is currently in site review to vacate Ponca Place and construct a very large addition - the bulk of which is parallel to Sioux and tight to the 25' setback line. The proposed structure would be more than 450 feet in length and 55 feet tall with four stories over a partially below grade parking structure. On the south side of the street are small detached single family structures, most only a single story and some less than 15 feet at the ridge of the roof. Land Use Current: High Density Residential land use and RH-5 zoning north of Sioux allows most of what Frasier is proposing (although 55 feet is outside the byright allowable height). Frasier has proposed vacation of the Ponca right-of-way to allow them to make their campus and structures even larger. Low Density Residential land use and RE zoning south of Sioux allows only single family detached structures. Duplex structures are allowed within the RE zone only if the lot size provides 7,500 sf per dwelling unit. The majority of the lots on the south side of Sioux are non-conforming and only about 11,000 sf. As a result, duplexes cannot be constructed there. Land Use Change Proposed South Side of Sioux: A Medium Density land use and RM-1 zone designation on the south side of Sioux would allow a narrow strip of slightly more dense housing between the RH-5 zone north of Sioux and the RE zone that would remain on the north side of Ricara and Shawnee. 22

The Medium Density land use and RM-1 zone designation would allow duplexes and even, potentially, small triplexes on the 11,000 sf lots on the south side of Sioux. This would allow two and three story structures. With the current RE zone an 11,000 sf lot could have a house of 4,222 sf in floor area and lot coverage of 3,166 sf. The house could be a maximum of 29.7 feet tall (due to the non-conforming lot size). With an RM-1 zone designation a triplex structure would require a minimum of 6,000 sf of open space. There would be no maximum floor area. The maximum building height would be 35’. The RM-1 zone would eliminate bulk plane, side wall articulation and solar access requirements. This would open the possibility for duplex/triplex townhomes or stacked flats along Sioux. And while these structures might be larger than the single family structures on Ricara and Shawnee they wouldn’t be significantly different. They would be a good “middle ground” between the urbanity of Frasier’s site and the suburban character of the remainder of the Keywaydin neighborhood. Missing Middle: Boulder is a city of primarily existing single family detached dwellings. It is becoming city of more dense, large multi-family housing. With the exception of maybe Whittier and University Hill, it is lacking in all of the other housing types that might support the “missing middle.” See Image A (credit to Opticos Design Inc.) The proposed land use change might provide the opportunity for missing middle housing. I don't think many people will find it desirable to live in a small detached single family suburban home on the south side of Sioux across the street from a structure of the scale Frasier is proposing. See Images B, D and F that illustrate the existing and/or forthcoming condition. Image D shows a cross section through Frasier’s proposed structure, the structure at 4700 Sioux and the structure at 4755 Shawnee. Image F shows the single family houses on the south side of Sioux superimposed on Frasier’s planned expansion on the north side. Two or three story duplex/triplex structures would be a better planning fit across the street from Frasier and probably more appealing to the people who would want to live across the street from such a large urban structure. See Images C and E showing a proposed intermediate zone of medium density housing. Image E shows a similar cross section as Image D but with a medium density triplex at 4700 Sioux Drive. I believe the requested land use change and concomitant zone change illustrated in Image C and Image E, would be a better planning solution to the issue of incompatible land uses on opposite sides of Sioux Drive and provide more diversity in housing types for different households with little or no impact on adjacent existing land uses. These structures could provide more housing for the "missing middle" in Boulder.

Yes

CRITERIA #2 – WITHIN THE POLICY LEVEL SCOPE OF THE COMPREHENSIVE PLAN

Yes

Is the request within the policy level scope of the Comprehensive Plan?

CRITERIA #3 – CAPACITY FOR TIMELY ANALYSIS Can the scope of the impact of the potential change be accommodated within the Comprehensive Plan update process and timeline?

Yes

X No

X 23

CRITERIA #4 – CONSISTENCY WITH PROPOSED PLAN DIRECTION Is the request consistent with the latest Comprehensive Plan policy and new draft Future Land Use Map direction?

Yes

Staff Recommendation: Yes, consider further under the new draft Future Land Use Map Staff recommends further consideration of this request within the context of the new draft Future Land Use Map. Although the Medium Density Residential (MR) land use designation will be consolidated through the Comprehensive Plan update, the request reflects the intent to introduce medium-density residential development in a neighborhood where high density housing exists directly north of Sioux Drive. The properties are well-served by existing transit, infrastructure, and nearby services, supporting efficient, compact development. This request is generally consistent with draft Comprehensive Plan policy and Future Land Use Map direction.

Request #11 Address: Request Type: Current Land Use: Proposed Land Use: Staff Recommendation:

2810 Olson Drive Land Use Map Change Low Density Residential (LR) Mixed Density Residential (MXR) Yes, consider further under the new draft Future Land Use Map

Applicant Narrative: The neighborhood is surrounded by higher density. It is also well served by public transportation options.

Yes

CRITERIA #2 – WITHIN THE POLICY LEVEL SCOPE OF THE COMPREHENSIVE PLAN

Yes

Is the request within the policy level scope of the Comprehensive Plan?

X No

CRITERIA #3 – CAPACITY FOR TIMELY ANALYSIS Can the scope of the impact of the potential change be accommodated within the Comprehensive Plan update process and timeline?

Yes

CRITERIA #4 – CONSISTENCY WITH PROPOSED PLAN DIRECTION Is the request consistent with the latest Comprehensive Plan policy and new draft Future Land Use Map direction?

Yes

X No

Staff Recommendation: Yes, consider further under the new draft Future Land Use Map Staff recommends further consideration of this request within the context of the new draft Future Land Use Map. Although the Mixed Density Residential (MXR) land use designation will be consolidated through the Comprehensive Plan update, the request reflects the intent to introduce medium-density residential development in a neighborhood currently surrounded by higher-density uses. The property is well-served by existing transit, infrastructure, and nearby services, supporting efficient, compact development. This request is generally consistent with draft Comprehensive Plan policy and Future Land Use Map direction.

Request #12 Address: Request Type: Current Land Use: Proposed Land Use: Staff Recommendation:

2855 & 2889 Valmont Road Land Use Map Change Open Space – Other (OS-O); Medium Density Residential (MR) Mixed-Use Business (MUB) Yes, consider further under the new draft Future Land Use Map

Applicant Narrative: This is a request to change the current Boulder Valley Comprehensive Plan (comp plan) designation on the properties at 2855 and 2889 Valmont Road from Mixed Use Residential (MR) to Mixed Use Business (MUB). The Boulder Valley Medical Center owns and occupies the existing buildings on the two properties and has been in operation for 52 years in Boulder (38 years at this location). The current RM-1 zoning allows for the continued use but a business zoning district would be more consistent with the existing use. The MUB comp plan designation would allow for a business zoning that is more conducive to the existing use and possible future expansion. The Valmont Road corridor continues to rapidly change and now functions as an important connector in Boulder from 55th Street to 28th Street. The City has significant commitments to transportation and infrastructure improvements that can support additional density and mixed uses in the area. The MUB comp plan designation is consistent with and furthers the City's core values to create compact, contiguous development and infill that supports evolution to a more sustainable form and neighborhood connectivity. The proposed comp plan designation is also compatible with the neighboring properties along Valmont Road that already have business zoning. Thank you for your consideration.

Yes

CRITERIA #2 – WITHIN THE POLICY LEVEL SCOPE OF THE COMPREHENSIVE PLAN

Yes

Is the request within the policy level scope of the Comprehensive Plan?

X No

CRITERIA #3 – CAPACITY FOR TIMELY ANALYSIS Can the scope of the impact of the potential change be accommodated within the Comprehensive Plan update process and timeline?

Yes

CRITERIA #4 – CONSISTENCY WITH PROPOSED PLAN DIRECTION Is the request consistent with the latest Comprehensive Plan policy and new draft Future Land Use Map direction?

Yes

X No

Staff Recommendation: Yes, consider further under the new draft Future Land Use Map Staff recommends further consideration of this request within the context of the new draft Future Land Use Map. Although the Mixed Use Business (MUB) land use designation will be consolidated through the Comprehensive Plan update, the request reflects the intent to introduce a designation that aligns with the existing medical and business uses on the properties and allows for potential future expansion. The property is well-served by existing transit, infrastructure, and nearby services, supporting efficient, compact development. This request is generally consistent with draft Comprehensive Plan policy and Future Land Use Map direction.

Request #13 Address: Request Type: Current Land Use: Proposed Land Use: Staff Recommendation:

1006 Lee Hill Drive Land Use Map Change Low Density Residential (LR) Mixed-Density Residential (MXR) or Medium-Density Residential (MR) Yes, consider further under the new draft Future Land Use Map

Applicant Narrative: 1006 Lee Hill Dr is a .95 acre parcel located on the southeast corner of 10th & Lee Hill Dr. bound by Zamia Ave to the south, 10th St to the west, Lee Hill Dr to the north & the CDOT highway maintenance facility to the east. The current land use designation for the site is Low Density Residential (LR) which generally allows for 2-6 units per acre. The site is currently zoned RL2 which likely needs to be amended given the change in circumstance surrounding the parcel. RL2 was explicitly excluded from the zoning and use code updates that were part of the Family Friendly Vibrant Neighborhoods (FFVN) project which “continued to evaluate the land use code for other modifications that could remove zoning barriers to housing units that are smaller, modest sized units, typically referred to as ‘missing middle’ housing, with a focus on transit corridors & walkable areas near downtown & neighborhood centers.” The reason for RL2’s exclusion as stated by Karl Guiler at the City Council Meeting on 4/25/24: “RL2 was not included in the FFVN report because it’s a little more complicated when it’s open space per dwelling unit and many of the dwelling units are actually in Planned Unit Developments or discretionary approvals from the past that would require amendments. We’re looking to hire a planner to do more analysis of RL2 and we didn’t want to make any changes before that analysis was done.” I followed up with Karl on 6/6/25 and was informed that the city does not have the staff resources to advance changes to the RL2 zoning district and that it was not going to be addressed in the BVCP update. He further explained the technicalities of the zoning district “in that most properties are governed by Planned Unit Developments (PUD), which are legally bound rights to how the properties were developed. Making changes to these PUDs is very involved from a technical and legal perspective.” No small task! However, 25 parcels (see attachment) are outliers to adjacent PUD’s. About half these parcels are churches, schools, or clubs and could have been constructed on parcels allocated to such uses as part of a PUD. However, there are 7 parcels of interest that appear to have never participated in the surrounding development. These parcels represent the opportunity to fulfill the intent of the FFVN within the RL2 zoning district and the solution could be to simply re-zone these parcels to what the city desires in their respective locations. 1006 Lee Hill Dr was annexed into the city in the 90s and was presumably given an RL2 zoning designation as part of a broader initiative to convert industrial land to residential on the west side of the Broadway neighborhood center. Large parcels were redeveloped over the years, the 29

former Boulder County Maintenance Facility immediately south and west of the subject property being the last large parcel to develop in 2016. The developer clustered open space south of Zamia and created a bifurcated outcome. South of Zamia Ave, the single family homes have a typical LR presentation with 5 units per acre. These single family homes are 1600-2000sf with prices from $1.3m-1.5m placing them in the upper tier just shy of luxury homes. West of the subject property, single family homes have a presentation more typical of MR at 9 homes per acre. These homes are 1600-2000sf and priced from $1.25m-1.45m. Given that 10th St would likely be the primary ‘front’ of the subject property under a redevelopment scenario, it would be reasonable to ‘book match’ the density on both sides of 10th St however the size and price of the units still makes them unattainable to the middle market and priced higher than the standard home in Boulder. North of the subject property, single family homes on both sides of 10th St from Lee Hill Dr to Lykins Ave present as typical MR at 8 homes per acre. The larger homes on smaller lots puts size at 1500-2500sf and pricing at $1m-1.3m which aligns with the median home value in Boulder but is still generally considered unattainable by the middle market. Things get interesting on 10th St between Lykins Ave & Chinle Ave, where single family homes, duplex’s & triplex’s present like MXR at 20 units per acre. Homes along 10th St between Lykins Ave and Chinle Ave have sizes from 800-1800sf and price points from $350k-$850k which exemplifies middle market housing while maintaining compatibility in form with the adjacent mix of residential densities. Considering the subject site’s proximity to a walkable neighborhood center, transportation corridors, multi-use paths, open space & parks, it’s an ideal location to meet the objectives of FFVN & the BVCP to bring balance and diversity to Boulders housing stock. In the theme of ‘A Boulder Future’ I’d like to request a land use designation of Mixed Density Residential with the vision of filling the need for affordable & middle market housing by placing a multiunit along Lee Hill Dr plus single family, duplex, and triplex homes along 10th St.

Yes

CRITERIA #2 – WITHIN THE POLICY LEVEL SCOPE OF THE COMPREHENSIVE PLAN

Yes

Is the request within the policy level scope of the Comprehensive Plan?

CRITERIA #3 – CAPACITY FOR TIMELY ANALYSIS Can the scope of the impact of the potential change be accommodated within the Comprehensive Plan update process and timeline?

Yes

CRITERIA #4 – CONSISTENCY WITH PROPOSED PLAN DIRECTION Is the request consistent with the latest Comprehensive Plan policy and new draft Future Land Use Map direction?

Yes

X No

Staff Recommendation: Yes, consider further under the new draft Future Land Use Map Staff recommends further consideration of this request within the context of the new draft Future Land Use Map. Although the Mixed Density Residential (MXR) land use designation will be consolidated through the Comprehensive Plan update, the request reflects the intent to increase housing diversity on the property while maintaining compatibility with surrounding development patterns. The site is well-connected to existing transit, bikeways, and neighborhood services, supporting compact, efficient development that aligns with Boulder’s housing objectives. This request is generally consistent with draft Comprehensive Plan policy and Future Land Use Map direction.

Request #14 Address: Request Type: Current Land Use: Proposed Land Use: Staff Recommendation:

1343 Iris Avenue Land Use Map Change Public (PUB) Mixed Use Transit-Oriented Development (MUTOD) Yes, consider further under the new draft Future Land Use Map

Applicant Narrative: Boulder County is the current owner of this land. This change request competes with their change request. This request is for a more specific type of land use, compared to theirs. My request is for the land to be zoned Mixed Use Transit- Oriented Development (MUTOD), which is a formal designation of the BVCP, but was not an option in this web form. This land is adjacent to several bus lines, with the Skip dominant, the 208 providing eastwest travel, and the line to Lyons going north. It is therefore very accessible to transit and should have a mixed land use, with both various housing types and retail and other commercial uses. The commercial uses will serve adjacent neighborhoods as well as providing services or products that people can utilize through non-automotive transport. Boulder needs this kind of development because we officially seek to reduce our carbon footprint. We cannot achieve that through our current system of mandatory car dependency. We must provide both alternative transportation and land uses that depend much less on automobile travel. The land use should specify that there will be minimal automobile parking with the intent of most access being by walking, bicycling, bus, and the various new forms of micro-mobility. Automobile parking will exist but will be priced separately from individual property units. Neighborhoods adjacent to this property are considered among the least walkable in Boulder. Adding commercial uses here will help address that problem. We need this kind of development also because we seek to provide a bigger supply of affordable or “attainable” housing, especially missingmiddle housing. So this parcel should not get a zoning that results in high-priced housing; i.e., single-family zoning. Housing types will predominantly service lower-middle and middle-income households, which means they will rent or sell at attainable or affordable prices. Some will be duplex, triplex, or quadplex with private areas of lawn and garden. Some will be medium density condos. Some will be high density apartments. There is no need for single-family zoning on this property. 32

All "open space" requirements in current zoning will be satisfied by permanent dedication of the eastern half of the property to public recreational use. Although the current use is baseball, that zoning can allow other sports and even a public park, playground, and picnic tables. The sale of this county property provides a fabulous opportunity to advance Boulder’s official environmental and housing goals. (But the sale is premature. The government planning should occur before the sale so potential buyers know in advance what uses are allowed.)

Yes

CRITERIA #2 – WITHIN THE POLICY LEVEL SCOPE OF THE COMPREHENSIVE PLAN

Yes

Is the request within the policy level scope of the Comprehensive Plan?

CRITERIA #3 – CAPACITY FOR TIMELY ANALYSIS Can the scope of the impact of the potential change be accommodated within the Comprehensive Plan update process and timeline?

Yes

CRITERIA #4 – CONSISTENCY WITH PROPOSED PLAN DIRECTION Is the request consistent with the latest Comprehensive Plan policy and new draft Future Land Use Map direction?

Yes

X No

Staff Recommendation: Yes, consider further under the new draft Future Land Use Map Staff recommends further consideration of this request within the context of the new draft Future Land Use Map. Although the Mixed Use TransitOriented Development (MUTOD) land use designation will be consolidated through the Comprehensive Plan update, the request reflects the intent to support a mix of residential, commercial, and public recreational uses in a transit-accessible location. The site is adjacent to multiple bus lines, is well-connected to neighborhood services, and can provide a range of housing types. This request is generally consistent with draft Comprehensive Plan policy and Future Land Use Map direction.

Request #15 Address: Request Type: Current Land Use: Proposed Land Use: Staff Recommendation:

1343 Iris Avenue Land Use Map Change Public (PUB) Mixed Use Residential (MUR) Yes, consider further under the new draft Future Land Use Map

Applicant Narrative: The Boulder County Commissioners’ plan to sell this property creates an excellent opportunity to address the acute shortage of attainable housing for middle income residents, in a way that reduces the need for automobile use - in line with our climate action goals. This area is ready-made for transit-oriented development, with the Skip, 208 and Lyons busses running immediately adjacent, and the 204 within reasonable walking distance. The planned safety improvements to Iris Avenue will make walking and bike use attractive to residents of this future neighborhood. I live adjacent to the Iris-Broadway property, in the Melody-Catalpa neighborhood. Though I enjoy the transit options mentioned above, my neighborhood is considered among the least walkable in Boulder. I would look forward quick, no-car access to cafes, shops and services that might be part of a nearby new residential-commercial neighborhood. I would like development of this property to be focused on the west side, preserving the public use designation on the east. This segment could provide a picnic area, playground and gardens, while preserving the much-beloved Little League fields that have existed there for decades. This “new” park would provide a vibrant amenity for both residents of new housing on the west side of the property and for adjacent older neighborhoods. I strongly feel that Boulder does NOT need more detached single-family or high-end (3K+ sq.ft. houses or luxury condos) housing. Any residential development on the parcel at Iris and Broadway should be created for middle income folks – singles, couples, or families – who fill essential jobs in Boulder but have difficulty affording a place to live. Thank you for considering a changed land-use designation at northwest Broadway & Iris that will help address Boulder’s interconnected housing, transit and climate goals

Yes

CRITERIA #2 – WITHIN THE POLICY LEVEL SCOPE OF THE COMPREHENSIVE PLAN

Yes

Is the request within the policy level scope of the Comprehensive Plan?

CRITERIA #3 – CAPACITY FOR TIMELY ANALYSIS Can the scope of the impact of the potential change be accommodated within the Comprehensive Plan update process and timeline?

Yes

CRITERIA #4 – CONSISTENCY WITH PROPOSED PLAN DIRECTION Is the request consistent with the latest Comprehensive Plan policy and new draft Future Land Use Map direction?

Yes

X No

Staff Recommendation: Yes, consider further under the new draft Future Land Use Map Staff recommends further consideration of this request within the context of the new draft Future Land Use Map. Although the Mixed Use Residential (MUR) land use designation will be consolidated through the Comprehensive Plan update, the request reflects the intent to support a mix of residential, commercial, and public recreational uses in a transit-accessible location. The site is adjacent to multiple bus lines, is wellconnected to neighborhood services, and can provide a range of housing types, while minimizing automobile dependence. This request is generally consistent with draft Comprehensive Plan policy and Future Land Use Map direction.

Request #16 Address: Request Type: Current Land Use: Proposed Land Use: Staff Recommendation:

2795 Colorado Avenue Land Use Map Change Low Density Residential (LR) High Density Residential (HR) Yes, consider further under the new draft Future Land Use Map

Applicant Narrative: Change the land use designation for our property to high density residential Justification: This change would better align faith-based and non-profit properties along Colorado Avenue with Boulder’s housing and community goals. These sites are uniquely located across from CU Boulder and along a key transit corridor, making them potentially well-suited for thoughtfully designed housing that supports students, staff, faculty, young families, and essential workers who are increasingly priced out of Boulder. Allowing more density on these properties maximizes community benefit, promotes equity and inclusion, and advances sustainability by placing housing in walkable, bikeable, and transit-rich areas. It also ensures the long-term presence of our faith-based institutions by creating opportunities to serve the broader community while sustaining our spiritual and service missions.

Yes

CRITERIA #2 – WITHIN THE POLICY LEVEL SCOPE OF THE COMPREHENSIVE PLAN

Yes

Is the request within the policy level scope of the Comprehensive Plan?

X No

CRITERIA #3 – CAPACITY FOR TIMELY ANALYSIS Can the scope of the impact of the potential change be accommodated within the Comprehensive Plan update process and timeline?

Yes

CRITERIA #4 – CONSISTENCY WITH PROPOSED PLAN DIRECTION Is the request consistent with the latest Comprehensive Plan policy and new draft Future Land Use Map direction?

Yes

X No

Staff Recommendation: Yes, consider further under the new draft Future Land Use Map Staff recommends further consideration of this request within the context of the new draft Future Land Use Map. Although the High Density Residential (HR) land use designation will be consolidated through the Comprehensive Plan update, the request reflects the intent to allow higherdensity residential development on a faith-based and non-profit property along Colorado Avenue. This site is well-located across from CU Boulder and near transit, services, and employment centers, making it suitable for thoughtfully designed housing for students, staff, faculty, young families, and essential workers. This request is generally consistent with draft Comprehensive Plan policy and Future Land Use Map direction.

Request #17 Address: Request Type: Current Land Use: Proposed Land Use: Staff Recommendation:

3975 28th Street Land Use Map Change Public (PUB); Open Space – Other (OS-O); Low Density Residential (LR) Medium Density Residential (MR) Yes, consider further under the new draft Future Land Use Map

Applicant Narrative: The Elks Club in North Boulder has a long history of providing a quasi-public property and swimming pool for the use of Boulder’s citizens. Multiple forces have changed the composition and leadership of the Elks in Boulder. This has led to a reevaluation of the possible uses of its facilities and how an Elks property land use change could potentially fit into the surrounding Boulder landscape. It is a change to the future land use which has led to this request. This request for a revision to the current land use designation is not without precedent on this property. In 2001 the Elks worked with the City of Boulder to sell Elk’s Park for permanent designation as a City park space. Along with this was a companion request to change land use designation on what was the eastern most portion of Elk property. Land use was changed during that process to allow the Sunrise Memory Care facility to be built in 2005. With this submittal we are respectfully requesting a Land Use Designation change from the existing P (Public) to MR (Medium Density Residential). This change would help set the stage for a zoning change that would allow the Elks to redevelop portions of their property consistent with the neighbors to the south and create a vibrant mixed-use community with a revitalized Elks facility at its center. Alignment with Goals of the BVCP Update: • Economic Vitality – through the community uses provided at an affordable cost, and through their philanthropic work, the Elks have helped fill needs not affordably met in other ways. Nationally, the Order spends more than $80,000,000 every year in their communities for scholarships and other philanthropy. • Environmental Sustainability – the introduction of medium density at this location, along with an affordable housing component, would allow folks now living outside of Boulder and commuting, to live in town at a location adjacent to our bikeway system and close to public transit. This would result in a large SOV trip reduction. • Healthy and Socially Thriving – we envision a connected community centered on the Elks club, where residents and visitors can socialize, exercise, and congregate. A change to MR would help the financial health of organization and allow their facilities to be updated to continue to serve the community. 38

• Livability – the Elks Park that was dedicated to the City along with the associated paths and connections make this location ideal for families to live and grow. The added benefit of proximity to revitalized Elks Club and pool could make a new neighborhood one of the most livable in Boulder. BCVP goals: • 1.08 Physical Expansion Limits – converting the currently underutilized land to medium density residential will help Boulder meet its substantial housing needs inside our current boundaries in well served and connected location. • 1.10 Growth – at a minimum, the addition of residential to the site would contribute 25% of units (or cash equivalent) to the affordable housing stock. • 1.11 Jobs/Housing Balance – the change to MR would allow the addition of housing with a minimum, if any, addition of commercial uses. • 1.12 Community Benefit – the Elks organization has been and plans to continue to be an enormous benefit to the community though their philanthropic work, and the provision of a community pool and gathering spaces. • 2.03 Compact Development – an MR designation would pave to the way to zoning that would allow for compact and efficient development of this underutilized property. • 2.14 Mix of Land Uses – we are requesting the MR designation, in part due to its consistency with neighboring land use to the south. • 2.16 Mixed Use – we envision a community that marries residential uses with a revitalized Elks Club – the mix of uses helping to create a vibrant neighborhood. • 4.01 Reduced Emissions – a well-connected, well served, medium density neighborhood would allow folks to live in town and avoid vehicles. • 4.07 Efficient Land Use – an MR designation allows for a much more efficient use of the land the current P zone would allow • 5.10 Role of Arts and Recreation – the Elks currently provides and plans to continue to provide a pool facility that gives Boulder families much needed affordable access to swimming opportunities. • 6.05 Reduction of SOV trips – a well-connected, well served, medium density neighborhood would allow folks to live in town and avoid vehicles. • 7.02 Affordable Housing – In addition to Inclusionary Housing requirements, we believe medium density housing could help contribute to the missing middle with duplexes, triplexes and other forms of family focused attached housing. • 7.07 Mix of Housing Types – an MR designation would allow for a wide variety of housing types. • 8.13 Community Facilities – the Elks Lodge includes not only the swimming pool, but multiple event and gathering spaces within the facility that are made available to the public. Respectfully submitted on behalf of the Boulder Elks

Yes

CRITERIA #2 – WITHIN THE POLICY LEVEL SCOPE OF THE COMPREHENSIVE PLAN

Yes

Is the request within the policy level scope of the Comprehensive Plan?

X No

CRITERIA #3 – CAPACITY FOR TIMELY ANALYSIS Can the scope of the impact of the potential change be accommodated within the Comprehensive Plan update process and timeline?

Yes

CRITERIA #4 – CONSISTENCY WITH PROPOSED PLAN DIRECTION Is the request consistent with the latest Comprehensive Plan policy and new draft Future Land Use Map direction?

Yes

X No

Staff Recommendation: Yes, consider further under the new draft Future Land Use Map Staff recommends further consideration of this request within the context of the new draft Future Land Use Map. Although the Medium Density Residential (MR) land use designation will be consolidated through the Comprehensive Plan update, the request reflects the intent to introduce medium-density residential housing while retaining community-serving recreational uses. The property is well-connected to existing transit, bikeways, and nearby services, supporting efficient, compact development. This request is generally consistent with draft Comprehensive Plan policy and Future Land Use Map direction.

Request #18 Address: Request Type: Current Land Use: Proposed Land Use: Staff Recommendation:

3825 Walnut Street Land Use Map Change Light Industrial (LI) Mixed Use Residential (MUR) Yes, consider further under the new draft Future Land Use Map

Applicant Narrative: We request changing the land use designation for 3825 Walnut Street from Industrial to Mixed Use Residential. This change would better reflect the current and anticipated conditions of the surrounding area, support Boulder’s updated comprehensive plan goals, and provide substantial community benefits by enabling housing and compatible uses in a location served by existing infrastructure and transit. Alignment with BVCP Goals The Boulder Valley Comprehensive Plan (BVCP) update emphasizes compact, sustainable growth, directing new development toward areas already served by municipal infrastructure and transit. Mixed Use Residential at 3825 Walnut Street aligns with these goals by providing opportunities for housing while supporting compatible commercial or service uses that activate the corridor. This approach reduces the need for greenfield development, concentrates growth in appropriate locations, and advances Boulder’s climate, equity, and livability objectives. The BVCP also highlights land use flexibility, recognizing that some legacy industrial areas may no longer serve the city’s highestpriority community needs. Addressing Housing Needs and Equity Boulder continues to experience a shortage of housing, particularly workforce and moderate-income units. Redeveloping this property for mixed use residential will contribute new housing supply while preserving some commercial or service activity on site. Locating housing near transit, employment centers, and services reduces commuting burdens, lowers transportation costs for households, and improves equitable access to opportunity. Mixed-use development also supports neighborhood vitality by fostering a more diverse and active streetscape. Climate and Transportation Benefits Mixed-use residential development encourages walking, biking, and transit use, reducing vehicle miles traveled and supporting Boulder’s greenhouse gas reduction targets. By situating housing in a location already served by transit and multimodal infrastructure, this change enhances mobility options and creates a more sustainable urban environment. Consistency with HB24-1313 41

Colorado House Bill 24-1313 directs local governments to facilitate housing in transit-oriented communities. 3825 Walnut Street is proximate to transit service, making it an ideal candidate for mixed-use residential development consistent with state law. The change also allows Boulder to leverage potential state infrastructure support for redevelopment, ensuring efficient use of public resources. Community Benefits and Mitigation Converting 3825 Walnut Street to mixed-use residential provides multiple benefits: Expanded housing supply in a central, accessible location. A more vibrant, active corridor by combining residential and compatible commercial uses. Reduced environmental impact through transit-oriented, compact development. Efficient use of existing infrastructure, reducing the need for extensions. Long-term land use flexibility, adapting to evolving community and market needs. Potential impacts to neighboring properties can be mitigated through thoughtful site design, including building orientation, setbacks, landscaping, and buffering. While preserving some industrial activity is valuable, this property’s location and underutilization make mixed-use residential a higher-priority community benefit. Conclusion Changing the land use designation for 3825 Walnut Street to Mixed Use Residential reflects current and anticipated conditions, supports BVCP housing, equity, and climate goals, aligns with HB24-1313, and delivers meaningful community benefits. This change enables Boulder to add housing in a well-served, transit-accessible location while creating a more vibrant, resilient, and sustainable corridor.

Yes

CRITERIA #2 – WITHIN THE POLICY LEVEL SCOPE OF THE COMPREHENSIVE PLAN

Yes

Is the request within the policy level scope of the Comprehensive Plan?

CRITERIA #3 – CAPACITY FOR TIMELY ANALYSIS Can the scope of the impact of the potential change be accommodated within the Comprehensive Plan update process and timeline?

Yes

CRITERIA #4 – CONSISTENCY WITH PROPOSED PLAN DIRECTION Is the request consistent with the latest Comprehensive Plan policy and new draft Future Land Use Map direction?

Yes

X No

Staff Recommendation: Yes, consider further under the new draft Future Land Use Map Staff recommends further consideration of this request within the context of the new draft Future Land Use Map. Although the Mixed Use Residential (MUR) land use designation will be consolidated through the Comprehensive Plan update, the request reflects the intent to introduce mixed-use residential development that provides housing while supporting compatible commercial or service uses. The property is well-served by transit, existing infrastructure, and nearby services, supporting efficient, compact growth. This request is generally consistent with draft Comprehensive Plan policy and Future Land Use Map direction.

Request #19 Address: Request Type: Current Land Use: Proposed Land Use: Staff Recommendation:

3156 28th Street; 3158 28th Street Land Use Map Change General Business (GB); Medium Density Residential (MR) Mixed Use Residential (MUR) Yes, consider further under the new draft Future Land Use Map

Applicant Narrative: We request changing the land use designation for 3156–3158 28th Street from split General Business (west) and Medium Density Residential (east) to Mixed Use Residential. Consolidating the property under a single high-density residential designation reflects current physical conditions, better supports BVCP housing goals, and positions the site to meet Boulder’s growing demand for housing near transit and services. BVCP Alignment The BVCP update encourages compact, infill development near existing infrastructure and transit corridors. Consolidating this site under a High Density Residential designation supports these objectives, allowing a coherent redevelopment strategy that maximizes housing potential, reduces greenfield development pressure, and aligns with city goals for equity, climate action, and land use flexibility. Housing and Equity Benefits This property is in a central, transit-accessible location where housing is in high demand. High-density residential use would provide additional units, diversify housing types, and reduce pressures on surrounding neighborhoods, advancing equity by providing more affordable transportation options and access to jobs, services, and amenities. Climate and Transportation Benefits High-density residential development encourages multimodal transportation, reduces vehicle miles traveled, and supports Boulder’s greenhouse gas reduction targets. Transit-accessible housing also fosters a more walkable, active, and connected community. Consistency with HB24-1313 HB24-1313 promotes housing in transit-oriented communities. This site is directly adjacent to transit infrastructure, making high-density residential development consistent with state law while also allowing the city to leverage potential infrastructure support for redevelopment. Community Benefits and Mitigation Consolidating land use and enabling high-density residential development would create a more vibrant, active corridor while using existing infrastructure efficiently. Future development can include landscaping, buffering, and building orientation to ensure compatibility with neighboring 44

commercial and medium-density uses. While commercial activity is important, the site’s location and infrastructure make residential use a higherpriority benefit for the community. Conclusion: Changing the land use designation to High Density Residential reflects current and future conditions, advances BVCP housing, climate, and equity priorities, supports state policy, and provides substantial community benefits by adding housing in a central, transit-accessible location.

Yes

CRITERIA #2 – WITHIN THE POLICY LEVEL SCOPE OF THE COMPREHENSIVE PLAN

Yes

Is the request within the policy level scope of the Comprehensive Plan?

CRITERIA #3 – CAPACITY FOR TIMELY ANALYSIS Can the scope of the impact of the potential change be accommodated within the Comprehensive Plan update process and timeline?

Yes

CRITERIA #4 – CONSISTENCY WITH PROPOSED PLAN DIRECTION Is the request consistent with the latest Comprehensive Plan policy and new draft Future Land Use Map direction?

Yes

X No

Staff Recommendation: Yes, consider further under the new draft Future Land Use Map Staff recommends further consideration of this request within the context of the new draft Future Land Use Map. Although the Mixed Use Residential (MUR) land use designation will be consolidated through the Comprehensive Plan update, the request reflects the intent to consolidate the property under a higher-density residential designation to maximize housing opportunities in a transit-accessible location. The property is well-served by existing transit, infrastructure, and nearby services, supporting efficient, compact development. This request is generally consistent with draft Comprehensive Plan policy and Future Land Use Map direction.

Request #20 Address: Request Type: Current Land Use: Proposed Land Use: Staff Recommendation:

1860 38th Street Land Use Map Change Light Industrial (LI) Mixed Use Residential (MUR) Yes, consider further under the new draft Future Land Use Map

Applicant Narrative: We request changing the land use designation for 1860 38th Street from Industrial to Mixed Use Residential to better reflect the site’s context and support Boulder’s updated comprehensive plan goals. Like the neighboring 1800 38th Street property, this site is underutilized for industrial purposes, and residential use would better serve current and projected community needs. BVCP Alignment The BVCP update prioritizes housing in locations already served by infrastructure and transit. This property is within a well-served corridor, allowing new residential development without the cost or environmental impact of extending infrastructure to new areas. Residential designation also supports BVCP objectives of land use flexibility, compact growth, and climate-conscious development. Addressing Housing Needs and Equity Boulder faces housing shortages and affordability challenges, particularly for workforce and moderate-income households. Redeveloping this site for residential use directly increases the housing supply and provides proximity to transit and services, enhancing access to opportunity and reducing transportation costs. Climate and Transportation Benefits New housing here encourages walking, biking, and transit use, reducing vehicle miles traveled and supporting Boulder’s climate goals. Locating residential development in a transit-accessible corridor maximizes multimodal connectivity and community sustainability. Consistency with HB24-1313 HB24-1313 encourages residential development in transit-oriented areas. 1860 38th Street is adjacent to a HB24-1313 designated transit corridor, making it a prime candidate for higher-density residential development consistent with state policy, while allowing the city to leverage potential infrastructure support. Community Benefits and Mitigation 46

Residential use contributes to a more vibrant and active neighborhood while efficiently using existing infrastructure. Site design can ensure compatibility with surrounding industrial and commercial uses through building orientation, landscaping, and buffering. While preserving industrial land is important, this property’s location and underutilization justify residential designation as a higher-priority community benefit. Conclusion Changing the land use designation to residential reflects evolving conditions, supports BVCP goals for housing, equity, and climate, aligns with state law, and maximizes the property’s contribution to Boulder’s transit-accessible, sustainable growth.

Yes

CRITERIA #2 – WITHIN THE POLICY LEVEL SCOPE OF THE COMPREHENSIVE PLAN

Yes

Is the request within the policy level scope of the Comprehensive Plan?

CRITERIA #3 – CAPACITY FOR TIMELY ANALYSIS Can the scope of the impact of the potential change be accommodated within the Comprehensive Plan update process and timeline?

Yes

CRITERIA #4 – CONSISTENCY WITH PROPOSED PLAN DIRECTION Is the request consistent with the latest Comprehensive Plan policy and new draft Future Land Use Map direction?

Yes

X No

Staff Recommendation: Yes, consider further under the new draft Future Land Use Map Staff recommends further consideration of this request within the context of the new draft Future Land Use Map. Although the Mixed Use Residential (MUR) land use designation will be consolidated through the Comprehensive Plan update, the request reflects the intent to introduce residential development on an underutilized site to better meet current and projected housing needs. The property is well-served by existing transit, infrastructure, and nearby services, supporting efficient, compact development. This request is generally consistent with draft Comprehensive Plan policy and Future Land Use Map direction.

Request #21 Address: Request Type: Current Land Use: Proposed Land Use Staff Recommendation:

1800 38th Street Land Use Map Change Light Industrial (LI) Mixed Use Residential (MUR) Yes, consider further under the new draft Future Land Use Map

Applicant Narrative: We request changing the land use designation for 1800 38th Street from Industrial to Mixed Use Residential. This property is currently underutilized for industrial purposes, and a residential designation would better reflect current and future conditions in the surrounding area, support Boulder’s updated comprehensive plan goals, and address pressing community housing needs. Alignment with BVCP Goals The Boulder Valley Comprehensive Plan (BVCP) update emphasizes compact, sustainable growth and encourages new housing in areas already served by infrastructure and transit. Residential use at 1800 38th Street aligns with these goals by leveraging existing water, sewer, transportation, and transit services, reducing the need for greenfield development, and concentrating growth in locations where it supports efficiency, livability, and climate action. The BVCP also emphasizes land use flexibility, recognizing that legacy industrial areas may no longer meet current economic or community priorities. Addressing Housing Needs and Equity Boulder faces an ongoing shortage of housing, particularly affordable and workforce housing. Converting this property to residential use provides new housing opportunities in a location that is accessible to jobs, services, and transit. Housing near transit reduces transportation costs, supports equitable access to opportunity, and improves community resilience. Climate and Transportation Benefits Residential development at this site reduces vehicle miles traveled, supports transit ridership, and encourages walking and biking. These outcomes help Boulder achieve its greenhouse gas reduction targets while promoting multimodal transportation. Consistency with HB24-1313 Colorado House Bill 24-1313 encourages municipalities to allow additional housing in transit-oriented areas. 1800 38th Street is within a HB2413-13 designated transit corridor, making it a strong candidate for residential development consistent with state law. The change also positions the city to leverage potential infrastructure funding to support redevelopment. 48

Community Benefits and Mitigation Residential use would provide a more vibrant, mixed-use neighborhood while using existing infrastructure efficiently. Future development could include design features to ensure compatibility with adjacent uses, including setbacks, landscaping, and thoughtful site orientation. While industrial land remains important for Boulder’s economy, this site’s location and underutilization make residential use a higher-priority community benefit. Conclusion: Changing the land use designation to residential reflects the current and future context, supports BVCP housing, equity, and climate goals, aligns with state law, and provides tangible community benefits by delivering new housing in a well-located, transit-accessible site.

Yes

CRITERIA #2 – WITHIN THE POLICY LEVEL SCOPE OF THE COMPREHENSIVE PLAN

Yes

Is the request within the policy level scope of the Comprehensive Plan?

CRITERIA #3 – CAPACITY FOR TIMELY ANALYSIS Can the scope of the impact of the potential change be accommodated within the Comprehensive Plan update process and timeline?

Yes

CRITERIA #4 – CONSISTENCY WITH PROPOSED PLAN DIRECTION Is the request consistent with the latest Comprehensive Plan policy and new draft Future Land Use Map direction?

Yes

X No

Staff Recommendation: Yes, consider further under the new draft Future Land Use Map Staff recommends further consideration of this request within the context of the new draft Future Land Use Map. Although the Mixed Use Residential (MUR) land use designation will be consolidated through the Comprehensive Plan update, the request reflects the intent to introduce residential development on an underutilized site to better meet current and projected housing needs. The property is well-served by existing transit, infrastructure, and nearby services, supporting efficient, compact development. This request is generally consistent with draft Comprehensive Plan policy and Future Land Use Map direction.

Request #22 Address: Request Type: Current Land Use: Proposed Land Use: Staff Recommendation:

East Ridge Subdivision Land Use Map Change Low Density Residential (LR) Medium Density Residential (MR) Yes, consider further under the new draft Future Land Use Map

Applicant Narrative: THIS APPLICATION IS FOR THE ENTIRE EAST RIDGE SUBDIVISION OF 40 PROPERTIES per What's Up Boulder visit and staff email Sept 11; SUPERMAJORITY SUPPORT DOCUMENTATION TO FOLLOW as directed "The best place to put more student housing is right between both CU Boulder academic campuses." There, I said it. The BVCP or Comp Plan is virtually silent on student housing (a major driver of our local economy with almost 39,000 students and the "elephant in the room"), which is the main reason staff will recommend against this proposal. But nearly all reasons and rationales provided by staff for increasing density in all efforts in the past few years also apply here, and are incorporated by reference. Boulder East Ridge, excluding multi-story office and residential buildings, is a small neighborhood of 40 detached houses between 28th and 30th, north of Colorado Ave. and south of Gold Run condominiums. It is the only neighborhood currently low density that is virtually adjacent to both main and east University of Colorado Boulder campuses and is essentially the “land bridge” between them. When this neighborhood was built circa 1955-1958 it stood alone. Since then CU has grown around it and it has also become essentially surrounded by higher density residential housing. It is already designated as part of the Colorado University sub-community in the Comp Plan p. 117. Since our previous land use change applications in the 2000’s, more CU academic departments have moved to east campus, and we are now essentially in the middle of the CU Engineering School. Due to its close proximity to both main and east CU campuses, the natural use of these properties is for student and staff housing. The land use designation should reflect the changes in the surroundings to help meet the demand for student housing, even if this is essentially ignored in the current BVCP. City Council Resolution 922 Part 3B states "Consider the potential for higher housing densities on parcels adjoining the University of Colorado." We are now virtually adjacent to both CU Boulder academic campuses. Redevelopment for private student housing continues along 28th St. and its Frontage Rd. between Baseline and Arapahoe. Lisa Morzel, former City Council and Planning Board member, said she used to live in this neighborhood while a student, and if any neighborhood should have higher density, it is this neighborhood. 50

Upon rezoning from low to medium density, I anticipate some duplex conversions, subject to off-street parking requirements. We are already a Neighborhood Parking Permit program neighborhood given our proximity to main campus. There will also probably be a few additional structures built and possibly a few pop-tops depending on lot size. This would help meet student housing demand in close proximity to academic campuses. This is largely sustainable use of existing structures to adjust to changes in surroundings. A land use change for our neighborhood would meet many criteria in the Comp Plan. BVCP Ch. 3 Policies Section 7 Housing goals to Support Community Housing Needs, Preserve & Enhance Housing Choices, and Integrate Growth & Community Housing Goals are all clearly met if students are considered. All 6 amendment criteria a-f p. 161 are met as part of the “Colorado University” sub-community. We are adjacent to 28th, 30th, and Colorado transportation corridors. We are within walking distance of 29th St., Basemar, The Village, and 30th/Baseline retail areas. Staff has previously been opposed to this land use change because of glaring omissions in the Comp Plan, that use of existing structures can and will change without change in the basic structures themselves due to changes in surroundings, and that student housing is essentially not addressed in the Comp Plan (nominally left for CU to address), a significant proportion of our population and the “elephant in the room.” There is already precedent for up-zoning moderate areas nearby, especially along the west side of 30th between Colorado and Baseline, that are adjacent to and largely surrounded by higher density. However, increasing the housing density of East Ridge will not set a precedent for increasing the density of other neighborhoods since no other low density neighborhoods have our particular location, virtually adjacent to not just one but two CU academic campuses, and are not already surrounded by higher density. When I moved into East Ridge 45 years ago, most houses were owner occupied. Now, with the changes in surroundings including the growth of CU, most houses are student rentals. Nearly all of us property owners would like to be able to better utilize our properties to help meet the demand for student housing in close proximity to both campuses, otherwise students will live elsewhere in the city. Changing the land use designation for East Ridge will be an appropriate step in adjusting to the changes in CU and the surrounding neighborhoods.

Yes

CRITERIA #2 – WITHIN THE POLICY LEVEL SCOPE OF THE COMPREHENSIVE PLAN

Yes

Is the request within the policy level scope of the Comprehensive Plan?

CRITERIA #3 – CAPACITY FOR TIMELY ANALYSIS Can the scope of the impact of the potential change be accommodated within the Comprehensive Plan update process and timeline?

Yes

X No

CRITERIA #4 – CONSISTENCY WITH PROPOSED PLAN DIRECTION Is the request consistent with the latest Comprehensive Plan policy and new draft Future Land Use Map direction?

Yes

Staff Recommendation: Yes, consider further under the new draft Future Land Use Map Staff recommends further consideration of this request within the context of the new draft Future Land Use Map. Although the Medium Density Residential (MR) land use designation will be consolidated through the Comprehensive Plan update, the request reflects the intent to introduce medium-density residential housing in a neighborhood adjacent to both University of Colorado Boulder campuses to better meet evolving housing needs. The property is well-served by existing transit, infrastructure, and nearby services, supporting efficient, compact development. This request is generally consistent with draft Comprehensive Plan policy and Future Land Use Map direction.

Request #23 Address: Request Type: Current Planning Area: Proposed Planning Area: Staff Recommendation:

5000 28th Street Planning Area Map Change Area III – Planning Reserve Area II Ineligible, do not consider further

Applicant Narrative: 5000 28th St is a 2.38 acre parcel located immediately east / southeast of the intersection of Broadway and 28th St. The site is bound by 28th St to the southwest, a vacant parcel to the north, and a commercially operated parcel owned by City of Boulder Housing and Human Services to the east (leased to Atlas Flooring). Currently, this site is part of the Area III Planning Reserve. I’d like to request changing this parcel from Area III Planning Reserve to Planning Area II. I understand this request is running in parallel with the broader discussion of Area III Planning Reserve but I submit this request separately with the intent of offering an alternative to a potential ‘all or nothing’ outcome of the broader conversation. It’s stated in BVCP Exhibit B Sec.A.2.a.ii that “While service area expansion into the Area III Planning Reserve may occur over time in several separate actions, it must result in a logical expansion of the Service Area.” The subject parcel’s unique location at a prominent intersection and with approximately ⅓ of it’s perimeter abutting existing city limits presents a logical opportunity to establish a beachhead from which to expand into the Area III Planning Reserve. By making this planning area change, it opens the door to possibilities and conversations with details and permissions to be worked out through annexation, zoning, and site plan review processes. It’s reasonable to envision the intersection of Broadway and 28th becoming a 4 way intersection with the new connecting street being the neighborhood arterial street that serves the future development of the broader Area III Planning Reserve. In addition to this transportation interconnect, this site could facilitate the underground utility interconnects and be a foundational building block to the future of the broader area. Considering the fact that this parcel abuts the 30 acre parcel immediately to the west which is owned by City of Boulder Housing and Human Services (4920 28th St), the establishment of the aforementioned 4 way intersection could facilitate future access and civil infrastructure being brought to the northwest corner of the City of Boulder owned property at 4920 28th St. Alternatively, it seems illogical that existing access off 28th St would remain when City of Boulder develops it’s parcel. This is a meaningful factor in considering the critical need being met by the annexation of all or any of the Area III Planning Reserve and I understand this critical need is currently being discussed. I don't think the subject parcel by it's self can really move the needle on filling the critical need for middle market and affordable housing. However, creating access to 30 acres of developable land would certainly move the needle in fulfilling this critical need. Possibilities beyond those being discussed more broadly around Area III Planning Reserve could include: annexing this parcel to allow for the relocation of an existing and critical service out from a site within existing city limits which would in turn allow for the redevelopment of the subsequently vacant site inside city limits (consider the possibilities! CDOT?). Alternatively, perhaps in the interim, this site could be a fun place to establish an art installation (think large sculptures like the dinosaurs on 93) that would 53

enhance the gateway to the city and play off the North Boulder Arts District. And further outside the box, could this be a site to re-establish an artistic version of the Holiday Drive-in Theatre ahead of the Sundance Film Festival? These creative interim ideas could conceivably become part of the North Boulder Sub Community Plan which has an emphasis on the arts. Beyond the obvious absence of municipal services, the existing Transitional Zoning under Boulder County jurisdiction establishes a very narrow range of possibilities for this property. An assignment of a Land Use Designation in line with it’s current use would be a welcomed backdrop to the current and intermediate term use of this site. Please know that ownership is eager to be an engaged partner with the City and County in both the near and long term visions for the Area III Planning Reserve.

Yes

CRITERIA #2 – WITHIN THE POLICY LEVEL SCOPE OF THE COMPREHENSIVE PLAN

Yes

Is the request within the policy level scope of the Comprehensive Plan?

N/A

CRITERIA #3 – CAPACITY FOR TIMELY ANALYSIS Can the scope of the impact of the potential change be accommodated within the Comprehensive Plan update process and timeline?

Yes

CRITERIA #4 – CONSISTENCY WITH PROPOSED PLAN DIRECTION Is the request consistent with the latest Comprehensive Plan policy and new draft Future Land Use Map direction?

Yes

N/A No

N/A

Staff Recommendation: Ineligible, do not consider further Staff does not recommend further consideration of this request. The request involves a change that cannot be made through the Community Change Request process. Under the Amendment Procedures outlined in Exhibit B of the Boulder Valley Comprehensive Plan, only the City may initiate amendments affecting properties within the Area III Planning Reserve; therefore, this request is not eligible to advance.

Request #24 Address: Request Type: Current Planning Area: Proposed Planning Area: Staff Recommendation:

6710 Arapahoe Road Planning Area Map Change Area III – Rural Preservation Area II Yes, consider further

Applicant Narrative: Westview Church is located at the southwest corner of Arapahoe Road and Westview Drive. The property consists of approximately 5.16 acres that borders the annexed Boulder Valley School District Education Center on the west boundary, and the City of Boulder owned land on the east. Currently the property consists of a 6,000 square foot sanctuary and fellowship space, and a 3,200 square foot residential dwelling with city water and sewer service supplied by the Hoover Hills Water and Sanitation District. In the basement below the sanctuary space there is a Forest School that is in operation five days each week (Monday-Friday). The remaining property (acreage) is open space that is not developed. Westview Church is a continuation of the congregation of the former Mount Calvary Lutheran Church (3485 Stanford Court) in south Boulder that is now home to the new Hilltop Affordable Senior Living Center. Following discussions with Planning Staff, Westview Church believes there are better opportunities for the future of the community by pursuing a Planning Area Designation change to allow for future annexation into the City of Boulder.

Yes

CRITERIA #2 – WITHIN THE POLICY LEVEL SCOPE OF THE COMPREHENSIVE PLAN

Yes

Is the request within the policy level scope of the Comprehensive Plan?

X No

CRITERIA #3 – CAPACITY FOR TIMELY ANALYSIS Can the scope of the impact of the potential change be accommodated within the Comprehensive Plan update process and timeline?

Yes

CRITERIA #4 – CONSISTENCY WITH PROPOSED PLAN DIRECTION Is the request consistent with the latest Comprehensive Plan policy and new draft Future Land Use Map direction?

Yes

X No

Staff Recommendation: Yes, consider further This request seeks a Planning Area Designation change for the Westview Church, located at the southwest corner of Arapahoe Road and Westview Drive, to allow potential future annexation into the City of Boulder. A Planning Area designation change from Area III – Rural Preservation to Area II would enable integration into the City’s municipal services. The property’s adjacency to city limits and the Boulder Valley School District Education Center, along with existing infrastructure, supports compact, efficient growth. This request is generally consistent with draft Comprehensive Plan policy and Future Land Use Map direction.

Request #25 Address: Request Type: Current Planning Area: Proposed Planning Area: Staff Recommendation:

810 Marshall Road Planning Area Map Change Area III – Rural Preservation Area II Yes, consider further

Applicant Narrative: To the Boulder Valley Comprehensive Plan Review Committee: I respectfully submit this request for a change in Area Designation for my property at 810 Marshall Road, Boulder, CO 80305, from Area III to Area II. This change would make the property eligible for City of Boulder services and consideration for future annexation. Property Overview: The subject property is a 2-acre parcel located in unincorporated Boulder County. It is bordered by CU South to the north, an Area I property undergoing significant planned development by the City and the University of Colorado. Along with two other small acreage remaining Area III adjacent properties, it is bordered by Table Mesa Village Mobile Home Park, a mediumdensity Area II neighborhood to the east and south. Rationale for Area II Designation: The parcel is surrounded by Area I and Area II-designated properties. It currently relies on an on-site wastewater treatment system, despite being adjacent to existing City sewer infrastructure. It lies within 600 feet of an active public transit line, further supporting urbanlevel serviceability and access. The Area III designation is no longer consistent with the BVCP’s long-term vision for urban infill, efficient infrastructure expansion, and sustainable community development. Continued classification as Area III does not align with the public health and safety interests of the community, particularly as surrounding development intensifies. Given these conditions, a reclassification to Area II would better reflect the property's physical context, infrastructure potential, and alignment with comprehensive planning principles. Thank you for your time and consideration of this request. Sincerely, Don Bushey

Yes

CRITERIA #2 – WITHIN THE POLICY LEVEL SCOPE OF THE COMPREHENSIVE PLAN

Yes

Is the request within the policy level scope of the Comprehensive Plan?

X No

CRITERIA #3 – CAPACITY FOR TIMELY ANALYSIS Can the scope of the impact of the potential change be accommodated within the Comprehensive Plan update process and timeline?

Yes

CRITERIA #4 – CONSISTENCY WITH PROPOSED PLAN DIRECTION Is the request consistent with the latest Comprehensive Plan policy and new draft Future Land Use Map direction?

Yes

X No

Staff Recommendation: Yes, consider further This request seeks a Planning Area Designation change for the property at 810 Marshall Road, Boulder, CO, to allow for potential future annexation into the City of Boulder. The site is currently served by an on-site wastewater treatment system but is adjacent to existing City sewer infrastructure and within 600 feet of active public transit. A Planning Area designation change from Area III – Rural Preservation to Area II would enable integration into City municipal services. The property’s proximity to surrounding Area I and II parcels, and existing infrastructure supports compact, efficient growth. This request is generally consistent with draft Comprehensive Plan policy and Future Land Use Map direction.

Request #26 Request Type: Current Policy # or Text Section: Staff Recommendation:

Policy or Text Change N/A No, do not consider further

Applicant Narrative: I actually cannot accurately answer the above existing policy and text fields so I just used "yes" on both. And will take this opportunity to add my concern. We and the BVCP should have a high-level requirement for a comprehensive commitment and approach to wildfire threat remediation. I am *well* aware of the current state of things esp. within the city of Boulder; my 5.3.25 Daily Camera opEd summarizes my journey since mid 2024, culminating in getting OSMP to formally add and operationalize (to what degree tbd) our wildfires' root cause, human ignition (hereinafter "HI"), and its mitigation and deterrence—which had been totally absent from both the city and county CWPPs, even though HI is prominently featured throughout the website and documents hosted by the National Wildfire Cohesive Strategy upon which at least the city CWPP is based. (https://www.dailycamera.com/2025/05/03/guest-opinion-bart-windrum-its-time-for-a-yellow-line-and-a-boulder-valley-wildfire-summit-2/ ) I'm calling for a Vision-level expressed regional commitment to combat this existentially threatening issue with its focus on the parcels and areas from which the threat primarily emanates. For cities that means urban-adjacent upwind. "Vision" level means a formalized, named, funded, and operationalized multi-pronged and sustained effort that produces meaningful results. "Meaningful" means data-driven and experientially-driven reduction of risk to all the relevant aspects: human ignition (root cause of nearly all our threatening fires), fuel loads, widespread structural hardening with equity aspects accounted for, and continued development of agencies' safe/effective response.

Yes

CRITERIA #2 – WITHIN THE POLICY LEVEL SCOPE OF THE COMPREHENSIVE PLAN

Yes

Is the request within the policy level scope of the Comprehensive Plan? CRITERIA #3 – CAPACITY FOR TIMELY ANALYSIS Can the scope of the impact of the potential change be accommodated within the Comprehensive Plan update process and timeline?

No X

Yes

No X

CRITERIA #4 – CONSISTENCY WITH PROPOSED PLAN DIRECTION Is the request consistent with the latest Comprehensive Plan policy and new draft Future Land Use Map direction?

Yes

Staff Recommendation: No, do not consider further Staff does not recommend further consideration of this request. However, the topic of wildfire mitigation is a core focus of the draft Boulder Valley Comprehensive Plan, including emphasis on resilience at the urban–wildland interface, hazard awareness, and regional coordination. This request highlights the importance of reducing wildfire risk, which aligns with the Plan’s broader intent to prioritize safety, climate resilience, and protection of the community. While the Comprehensive Plan already addresses wildfire mitigation at a vision level, the specific operational elements suggested in the request such as parcel-level targeting, human ignition mitigation, fuel management, structural hardening, and emergency response improvements are implementation strategies that fall outside the policy level scope of the Comprehensive Plan update. These operational steps would be more appropriately considered in coordinated City and County programs, funding initiatives, and multi-agency wildfire mitigation strategies. Staff recognizes the alignment of this request with the Comprehensive Plan vision for wildfire safety, while also recognizing that the detailed, actionable components are inappropriate for the Plan’s policy-level framework.

Request #27 Request Type: Current Policy # or Text Section: Staff Recommendation:

Policy or Text Change 9.01 Support for Agriculture No, do not consider further

Applicant Narrative: Proposed addition to BVCP text in Section 9, Food and Agriculture: “Section 9.01A: Sustainable Water Use: Boulder’s Ag-water delivery system depends on 160-year-old legacy irrigation ditches, which present many opportunities for system upgrades to minimize water loss and maximize the yield of dwindling water supplies. The City and County will partner with local ditch companies, farmers and ranchers to upgrade our Ag-water delivery systems to maximize Ag-water efficiencies, and to ensure the survival of viable agriculture in the Boulder Valley.” Explanation: Supplemental irrigation is imperative for successful agriculture on Boulder’s arid Front Range. Boulder Valley Ag-water supplies are under pressure from both climate change and stressors to the Colorado River and C-BT water. At the same time as droughts and increasing summer heat indexes require additional water for crops, diminishing snow packs and downstream demands on the Colorado River are reducing available water for agriculture. Boulder’s non-profit ditch companies maintain their ditches on shoe-string budgets, with limited capacity for infrastructure upgrades. Upgrades to watering systems are also out of reach of many OSMP and BCPOS lessees as they have only 3 to 5-year-long lease contracts. Our Ag-water users and providers need the City’s and County’s help to make Ag-water upgrades. Some of the ways the City and County could jump-start Agwater upgrades include: 1. Increase OSMP & BCPOS investment to Ag-water delivery systems supplying OSMP & BCPOS lands 2. Increase the use of volunteer, AmeriCorps and Ready-to-Work crews to maintain ditches 3. Provide grant writing assistance to ditch companies and lessees for EQIP and CWCB grants and loans. 4. Fund a grant program for ditch companies to make Ag-water delivery system upgrades This proposed addition to the BVCP ensures that agriculture remains viable in the Boulder Valley in the face of looming water shortages by building on current BVCP policies, such as: • Section 3.13: “The city and county will promote the conservation of water resources through…policies that promote efficient water usage” • Section 3.27: “Water resource planning efforts will…consider climate change and incorporate the goal of water…conservation” • Section 9.01: “The city and county will emphasize the importance of sustainable water use” and “will support farmers and ranchers in this area as they negotiate the challenges of operating in a semi-arid environment”. Possible Ag-water upgrades which will maintain local agriculture in the Boulder Valley by maximizing the beneficial use of every drop of our Agwater include: 61

• • • • • • • • • •

installing pivots or other more efficient sprinkler irrigation switching from flood irrigation to drip systems or gated irrigation pipe where appropriate installing irrigation ponds and pumps for farms to extend their water season solarizing electric & diesel pumps lining sections of leaking earthen ditches installing telemetry on water measuring flumes rebuilding headgates metering water flow to direct users installing divider boxes maintaining tail water ditches for return flows.

We must keep our rural lands in green cover, with living roots, to provide their full ecosystem benefits to Boulder Valley residents, and to mitigate climate change by sequestering CO2 in soils. Without supplemental irrigation, our Ag-lands will rapidly desertify, losing CO2 to the atmosphere as climate change intensifies, and will produce more dust storms, grass fires, soil erosion and reflected heat. The future benefits which well-irrigated Ag-lands can provide to our citizens - local food, cooling of neighboring heat islands, wildlife habitats, soil carbon sequestration and pastoral viewscapes - all depend on increasing the efficiency of our Ag-water delivery systems. Working in partnership with Boulder farmers, ranchers and irrigation ditch companies, the City and County can contend with our future Ag-water supply challenges and ensure the survival of local agriculture and all its ecosystem benefits. For background information on Colorado River shortages which will affect Boulder Valley municipal and Ag-water supplies, go to https://gcrg.us18.list-manage.com/track/click?u=b2ce3363654c27c81b37333a7&id=9dec8fd895&e=dbcefe57ba. This report says that if both precipitation and California & Arizona water withdrawals stay the same as in 2025, by the end of 2027, Lakes Mead and Powell will both reach functional “Dead Pool”. California & Arizona will then strong-arm Colorado to send more of its water downstream to them. Boulder uses Colorado River water in Gross Reservoir, South Boulder Creek, and as CB-T shares, which fill Boulder Reservoir, supply summer water to city residents, and keep our farms and rural lands irrigated and green. I strongly urge you to read this report and consider its implications carefully for all the agricultural and ecosystem services which the Boulder Valley so carefully stewards.

Yes

CRITERIA #2 – WITHIN THE POLICY LEVEL SCOPE OF THE COMPREHENSIVE PLAN

Yes

Is the request within the policy level scope of the Comprehensive Plan?

X No X

CRITERIA #3 – CAPACITY FOR TIMELY ANALYSIS Can the scope of the impact of the potential change be accommodated within the Comprehensive Plan update process and timeline?

Yes

CRITERIA #4 – CONSISTENCY WITH PROPOSED PLAN DIRECTION Is the request consistent with the latest Comprehensive Plan policy and new draft Future Land Use Map direction?

Yes

No X No

Staff Recommendation: No, do not consider further Staff does not recommend further consideration of this request. The proposed policy addition addressing sustainable Ag-water use and modernization of irrigation infrastructure aligns broadly with the draft Boulder Valley Comprehensive Plan’s emphasis on supporting viable agriculture, efficient water use, and climate resilience. The request highlights important challenges facing agricultural water systems under changing climate and water supply conditions, which are already reflected in existing and draft comprehensive plan policy direction. However, the specific elements of the request such as funding mechanisms, partnerships with ditch companies, infrastructure upgrades, and onsite farm irrigation improvements are implementation strategies that fall outside the scope of the Comprehensive Plan’s vision-level framework. Additionally, for Boulder County, policies related to supporting private ditch infrastructure are more appropriately considered at a countywide scale rather than within the geographically limited Comprehensive Plan planning area. As the draft Comprehensive Plan already addresses sustainable water use and agricultural viability at a high level, there is no need to advance this specific policy addition further. The detailed actions described in the request are better addressed through existing water management programs, capital planning, grant programs, and interagency implementation efforts.

Request #28 Request Type: Current Policy # or Text Section: Staff Recommendation:

Policy or Text Change N/A Ineligible, do not consider further

Applicant Narrative: Under Exhibit B: Boulder Valley Comprehensive Plan - Amendment Procedures A. Types of Changes 1. Land Use Map Changes Decision-making: Change "Land Use Map changes in Area I and II are a city decision, with call up to the county as described in the referral & call up procedures. Changes in Area III are a city and county decision" to: "Land Use Map changes in Area I are a city decision. Changes in Area II and Area III are a city and county decision." Also, under 2. Area II/III Boundary Changes Decision Making: Change "Minor Adjustments to the Service Area boundary are a city decision for areas five acres and under. For areas greater than five acres, the Board of County Commissioners may call up a city decision for its review under the procedures described below." to: "Minor Adjustments to the Service Area boundary are a city and county decision." Also, make these changes on the Summary Matrix on page 160 of the BVCP. The Boulder Valley Comprehensive Plan is a joint policy document legislatively adopted by the City of Boulder and Boulder County. Area II and Area III properties are in unincorporated Boulder County and decisions concerning these properties should have full County input. Citizens owning and residing on these properties outside the City of Boulder boundary are unable to vote in City of Boulder elections for City Council and city ballot issues. If Land Map Changes and Adjustments to the Service Area boundary for these properties are only a City of Boulder decision (without voting decisions from the County Commissioners and the County Planning Commission) then that is legislation without representation for those citizens who own and reside on those Area II and Area III properties. This needs to be corrected.

Yes

CRITERIA #2 – WITHIN THE POLICY LEVEL SCOPE OF THE COMPREHENSIVE PLAN

Yes

Is the request within the policy level scope of the Comprehensive Plan?

N/A

CRITERIA #3 – CAPACITY FOR TIMELY ANALYSIS Can the scope of the impact of the potential change be accommodated within the Comprehensive Plan update process and timeline?

Yes

N/A No

N/A

CRITERIA #4 – CONSISTENCY WITH PROPOSED PLAN DIRECTION Is the request consistent with the latest Comprehensive Plan policy and new draft Future Land Use Map direction?

Yes

N/A

Staff Recommendation: Ineligible, do not consider further Staff does not recommend further consideration of this request. The request proposes changes to the Amendment Procedures for Land Use Map and Area II/III boundary decisions. These procedures are contained in the Intergovernmental Agreement (IGA) between the City of Boulder and Boulder County and, while included in the Comprehensive Plan for reference, are not formally part of the plan itself. As such, the Community Change Request process cannot directly modify these procedures.

Request #29 Request Type: Current Policy # or Text Section: Staff Recommendation:

Policy or Text Change N/A Ineligible, do not consider further

Applicant Narrative: Comments from Westland Development Services, Inc. (“Westland”) regarding the East Boulder Subcommunity Plan & Station Area Master Plan: Westland and its President, Peter Aweida, are proponents of the East Boulder Subcommunity Plan and the Station Area Master Plan (the “STAMP Area Plans”). Mr. Aweida served on the East Boulder Working Group and the STAMP Subcommittee, in connection with the City’s development and adoption of the STAMP Area Plans. Westland owns over a dozen commercial properties in and around the STAMP Area (and elsewhere in Boulder) and provides a variety of light industrial / flex / manufacturing / retail / restaurant / gallery and office spaces for local businesses. Westland’s comments concern “office” uses in the STAMP Area, specifically "medical office" uses. Since the City’s adoption of the STAMP Area Plans, the BCH Foothills Hospital Campus has continued to grow, develop and influence East Boulder and particularly the STAMP Area around 55th & Arapahoe. From the BCH Campus on the West, traveling along Arapahoe Ave. to 55th St. on the East, there is growing influence from the BCH Campus and increased pressure for the area to accommodate new medical office uses and complementary health services. However, the City’s own Land Use Code (LUC) is not aligned with these current conditions influencing the STAMP Area, and the City’s LUC Appendix K actually conflicts with several of the Vision Statements, Outcomes and Policies expressed in the STAMP Area Plans. For example, East Boulder Plan Outcomes purport to “improve access to services that benefit health and wellbeing” including “health services”. Another desired Outcome is to foster and create “opportunities for new types of services to locate in East Boulder.” While some of the desired Outcomes appear to be happening in and immediately adjacent to the BCH Campus, in the nearby off-site areas, additional new medical office and complimentary health services are discouraged and prohibited from locating in the STAMP Area. The STAMP Area is seeing increased demand from hospital affiliates, doctors, medical groups, and related health service providers seeking to locate and integrate new medical practices near the BCH Campus, close to existing services and amenities around 55th & Arapahoe. The STAMP Plan recognizes that the City should encourage the “opportunity for increased mix of uses,” and the Plan specifically recommends that the City should “apply zoning that aligns with the uses and locations” of the STAMP Area. Unfortunately, the City’s own Land Use Code (LUC, Appendix K) presents obstacles by prohibiting “medical office” uses in the STAMP Area, even as conditional uses where the City could reasonably control the conditions for any new re-development. New medical office and health services uses are discouraged by Appendix K and re-directed to East Pearl, despite the growing influence of BCH Campus and existing Vision Statements in the STAMP Area Plans. Although the existing Plans purport to foster and encourage “S.T.E.A.M. Zone” uses (specifically including medical) in the STAMP Area, regrettably, several of Westland’s existing multi-story office buildings: (i) 5445 Conestoga Court (ii) 5450 Western Ave (iii) 1600 Range and (iv) 1705 Range, have been forced to turn away medical / health services providers seeking to locate new uses in the STAMP Area. On one hand, the 66

BCH Campus and STAMP Area Plans create pressure on the STAMP Area to accommodate new health services, but on the other hand, the City’s own LUC Appendix K discourages medical office uses. The result is forcing new users away from East Boulder to relocate in more hospitable areas including Longmont, Louisville, and Lafayette. As the STAMP Plans acknowledge, “current land use designations and zoning have created constraints” to reaching the stated goals of the STAMP Area Plans. Therefore, as the Plans themselves suggest, it is Westland’s request that the City “review the City’s building and land use codes and remove unnecessary barriers.” Specifically, Westland requests that the City review LUC Appendix K in connection with reviewing the STAMP Area Plans, and reconsider allowing “medical office” as a conditional use in the STAMP Area, especially in existing established office buildings. Thank you for your consideration.

Screen Screening Analysis: CRITERIA #1 – CONSISTENCY WITH COMPREHENSIVE PLAN GOALS Accessible & Connected, Economically Vital, Environmentally Sustainable, Healthy and Socially Thriving, Livable, Responsibly Governed, Safe

Yes

CRITERIA #2 – WITHIN THE POLICY LEVEL SCOPE OF THE COMPREHENSIVE PLAN

Yes

Is the request within the policy level scope of the Comprehensive Plan?

N/A

CRITERIA #3 – CAPACITY FOR TIMELY ANALYSIS Can the scope of the impact of the potential change be accommodated within the Comprehensive Plan update process and timeline?

Yes

CRITERIA #4 – CONSISTENCY WITH PROPOSED PLAN DIRECTION Is the request consistent with the latest Comprehensive Plan policy and new draft Future Land Use Map direction?

Yes

N/A No

N/A

Staff Recommendation: Ineligible, do not consider further Staff does not recommend further consideration of this request. The request relates to the City’s Land Use Code (Appendix K) and the allowance of conditional uses in existing buildings. These regulations are governed by the Boulder Revised Code, not the Comprehensive Plan. The Comprehensive Plan provides high-level policy guidance and land use designations, but it does not regulate conditional uses or detailed zoning allowances. Changing Appendix K to allow medical office uses would therefore require a Boulder Revised Code amendment, following the city’s formal code amendment process.

Request #30 Request Type: Current Policy # or Text Section: Staff Recommendation:

Policy or Text Change 2.07 Delineation of Rural Lands No, do not consider further

Applicant Narrative: Under Community Identity & Land Use Pattern 2.07 Delineation of Rural Lands Change: "The Boulder Service Area includes urban lands in the city and lands planned for future annexation and urban service provision." to: "The Boulder Service Area includes urban lands in the city and lands that may be annexed into the city in the future if there is an interest by the residents of those Area II areas." Also under 2.07 add this paragraph: "c) Area II Area II lands provide a buffer between Rural Area III lands and Urban Area I lands. The majority of the residences in Area II are zoned County Rural Residential with either Low Density Residential or Very Low Density Residential Land Use Designations in the Boulder Valley Comprehensive Plan. The rural character of these Area II land will be preserved." Reason: There has been very low interest in annexation into the City of Boulder from residents in Area II over many years. The residents in Area II prefer a more rural, less dense community and not a busy, dense, urban way of life that is confined to city living. This is why many of them have chosen to live outside City of Boulder boundaries in more rural, quiet, and less bustling neighborhoods. If the City of Boulder needs or wants to grow it should do so within its own boundaries and not impose that growth on surrounding unincorporated areas. Also, Area II lands provide a buffer between urban Area I lands and rural Area III lands.

Yes

CRITERIA #2 – WITHIN THE POLICY LEVEL SCOPE OF THE COMPREHENSIVE PLAN

Yes

Is the request within the policy level scope of the Comprehensive Plan?

No X No

CRITERIA #3 – CAPACITY FOR TIMELY ANALYSIS Can the scope of the impact of the potential change be accommodated within the Comprehensive Plan update process and timeline?

Yes

CRITERIA #4 – CONSISTENCY WITH PROPOSED PLAN DIRECTION Is the request consistent with the latest Comprehensive Plan policy and new draft Future Land Use Map direction?

Yes

No X No X

Staff Recommendation: No, do not consider further Staff does not recommend further consideration of this request. Annexation into the City of Boulder requires the property owner’s initiation through a property owner petition; under state law the City cannot forcibly annex an Area II property. Existing Comprehensive Plan policy already reflects this principle; however, staff recognizes that this could be clarified and that community concerns regarding forced annexation may be relieved by doing so. The Comprehensive Plan does not anticipate rural-character preservation in Area II as these lands are already developed at a suburban scale. Lands intended for long-term rural preservation are specifically designated as Area III-Rural Preservation. Staff does not recommend the policy be changed to consider Area II a Rural Preservation Area.

Request #31 Request Type: Current Policy # or Text Section: Staff Recommendation:

Policy or Text Change 2.35 Building Height No, do not consider further

Applicant Narrative: At the end of 2.35 it should read: (as described in Policy 1.12). It now has Policy 1.11 there. 1.11 is for Jobs: Housing Balance. 1.12 is for Enhanced Community Benefit. I am requesting to add on to the end of 2.35 paragraph the following text: "A community benefit will not guarantee additional building height. Aesthetics, view protection, and community input will be given very high consideration in deciding whether or not to allow additional building height." Reason: The impact of additional building height will be the same to the surrounding community whether or not there is a community benefit in the building or not. The effects of additional building height on the surrounding community needs to take preference over any community benefit. There may be developments where a community benefit is provided and the additional height has no or minimal impact on aesthetics, view protection, or the surrounding community. These developments could be given consideration for additional building height in the site review. However, if the additional height requested in a project has negative effects on aesthetics, view protection, and the surrounding community, it should not be given the additional building height just because it is providing a community benefit. The height restrictions need to be maintained in the Boulder Valley in order to protect the aesthetics, views, and community character of Boulder Neighborhoods and Centers.

Yes

CRITERIA #2 – WITHIN THE POLICY LEVEL SCOPE OF THE COMPREHENSIVE PLAN

Yes

No X

Yes

X 70

CRITERIA #4 – CONSISTENCY WITH PROPOSED PLAN DIRECTION Is the request consistent with the latest Comprehensive Plan policy and new draft Future Land Use Map direction?

Yes

Staff Recommendation: No, do not consider further Staff does not recommend further consideration of this request. The requested correction to the policy reference at the end of Section 2.35, changing it from Policy 1.11 to Policy 1.12, is accurate and will be incorporated as administrative correction. The Boulder Revised Code already provides that decisions regarding additional building height are evaluated through site-specific review processes (see section 9-2-14), which consider aesthetics, view protection, and community input. This ensures that community impacts are appropriately weighed when determining allowable height.

Request #32 Request Type: Current Policy # or Text Section: Staff Recommendation:

Policy or Text Change 1.17 Annexation No, do not consider further

Applicant Narrative: Under 1.17 i. Change the following sentences: "Although interest in voluntary annexation has been limited, the city and county continue to support the eventual annexation of Gunbarrel. If resident interest in annexation does occur in the future, the city and county will negotiate new terms of annexation with the residents." to: "Although interest in voluntary annexation has been limited, if resident interest in the annexation of Gunbarrel does occur in the future, the city and county will negotiate new terms of annexation with the residents." Reason: Over many decades, the interest from residents of unincorporated Gunbarrel for annexation into the City of Boulder has been very low to none. The protection of the rural character of the Gunbarrel area is very important to the citizens of Gunbarrel and higher density and urbanization are of little interest to them. The Area II and Area III lands in Gunbarrel do not need to be annexed into the City of Boulder. The Gunbarrel community can work together with the City of Boulder and Boulder County to further the policies of the Boulder Valley Comprehensive Plan while also protecting the rural character of Unincorporated Gunbarrel. Requests for annexation of Unincorporated Gunbarrel into the City of Boulder should come from the citizens of Unincorporated Gunbarrel and not be dictated by the City of Boulder.

Yes

CRITERIA #2 – WITHIN THE POLICY LEVEL SCOPE OF THE COMPREHENSIVE PLAN

Yes

Is the request within the policy level scope of the Comprehensive Plan?

CRITERIA #3 – CAPACITY FOR TIMELY ANALYSIS Can the scope of the impact of the potential change be accommodated within the Comprehensive Plan update process and timeline?

Yes

No X No

CRITERIA #4 – CONSISTENCY WITH PROPOSED PLAN DIRECTION Is the request consistent with the latest Comprehensive Plan policy and new draft Future Land Use Map direction?

Yes

No X

Staff Recommendation: No, do not consider further Staff does not recommend further consideration of this request. The City and County continue to support the eventual annexation of Gunbarrel. Gunbarrel contains major employment centers and already adjoins city-served infrastructure, including water, sewer, and multimodal transit corridors, making it a logical candidate for service integration. Annexation would remain entirely contingent on initiation by the residents of Gunbarrel. This approach maintains the Plan’s long-term aspirational guidance for urban expansion while respecting the community’s rural character and the principle of voluntary annexation.

Request #33 Request Type: Current Policy # or Text Section: Staff Recommendation:

Policy or Text Change Land Use Map accuracy No, do not consider further

Applicant Narrative: On the previous question I could only provide one designation, however this request is for more than one property and more than one designation - therefore other designations are requested in this Change in Land Use Request. I made this request during the 2020 Boulder Valley Comprehensive Plan (BVCP) mid-term update. Staff recommended at that time that my request not be considered further as part of the 2020 BVCP Mid-Term Update and wrote: "While this effort is not within the scope of the mid-term update, staff is anticipating this effort to be completed in the next major update to the comprehensive plan." We are now at the next major update of the BVCP during this 2025 Update. More details on my 2020 BVCP mid-term update request can be found on pages 107-115 at https://documents.bouldercolorado.gov/WebLink/DocView.aspx?id=172861&dbid=0&repo=LF8PROD2 as well as pages 22-26 at https://pub-bouldercounty.escribemeetings.com/FileStream.ashx?DocumentId=3044 Page 26 of this document lists additional open space-related changes to be addressed prior to or during the next BVCP Major Update. These and other properties need to be updated for accuracy in this 2025 BVCP Major Update. Please review my 2020 BVCP mid-term change of land use request as well as city and county documents associated with that request. During this 2025 major update of the BVCP, I am resubmitting my 2020 BVCP midterm change in land use request which requested for the review of land use designations in the unincorporated areas (and possibly some in the City of Boulder boundary) of the BVCP to ensure their accuracy and also to a change in the range of colors used on the BVCP Land Use Map for Open Space (Acquired), Open Space (Development rights), and Open Space (Other) to improve readability.

Yes

CRITERIA #2 – WITHIN THE POLICY LEVEL SCOPE OF THE COMPREHENSIVE PLAN

Yes

Is the request within the policy level scope of the Comprehensive Plan?

CRITERIA #3 – CAPACITY FOR TIMELY ANALYSIS Can the scope of the impact of the potential change be accommodated within the Comprehensive Plan update process and timeline?

Yes

X No

X 74

CRITERIA #4 – CONSISTENCY WITH PROPOSED PLAN DIRECTION Is the request consistent with the latest Comprehensive Plan policy and new draft Future Land Use Map direction?

Yes

No X

Staff Recommendation: No, do not consider further Staff does not recommend further consideration of this request. The draft Comprehensive Plan consolidates open space into a single designation and removes separate classifications including the Open Space categories previously referenced by the applicant, such as Open Space (Acquired), Open Space (Development Rights), and Open Space (Other). Because these classifications are not carried forward in the draft Comprehensive Plan, staff does not recommend they be considered further as part of this request. Further, land use map accuracy and legibility improvements, including color updates, are already underway through the drafting of the new Future Land Use Map.

Request #34 Request Type: Current Policy # or Text Section: Staff Recommendation:

Policy or Text Change Section 6 Transportation; policy 6.01 to policy 6.22 Yes, consider further

Applicant Narrative: Please see Attachment C: Community Cycles Change Request

Yes

CRITERIA #2 – WITHIN THE POLICY LEVEL SCOPE OF THE COMPREHENSIVE PLAN

Yes

Is the request within the policy level scope of the Comprehensive Plan?