Attachment A - Rezoning Written Statement

Attachment C - Rezoning Written Statement

MEMORANDUM To: From: Project: Date:

Charles Ferro, Land Use Review Manager - CITY OF BOULDER Adrian Sopher - SOPHER SPARN ARCHITECTS LLC HUB BOULDER ARAPAHOE – 2130 Arapahoe Avenue 7 May 2025 – Modified 5 August 2026 for compliance with BVCP 2025 Major Update

Re: WRITTEN STATEMENT – Land Use Map change & Rezoning Submittal MODIFICATIONS TO THE ORIGINAL WRITTEN STATEMENT: Application for a Land Use Map Change & Rezoning of 2130 Arapahoe was originally made in May of 2025, well before the adoption of the 2025 Update to the Boulder Valley Comprehensive Plan. It is therefore our understanding that, although our pending applications are governed by the 2015 BVCP, we may choose to be subject to the recently-adopted 2025 BVCP. Recognizing that the 2025 Update incorporated a Land Use Map change that fundamentally accomplishes the requested modification made via application, we are hereby electing to be subject to the 2025 BVCP, asking that that the application for land use change be rescinded, and that the application for rezoning be considered under the 2025 Update to the Comp Plan. The purpose of this Revised Written Statement is to weave in the Policies and Goals of the presumed (as of this writing) adoption of the 2025 Major Update to the BVCP in support of the application. 1. BACKGROUND – The need for High Density Housing Proximate to the University of Colorado CHANGES AT NAROPA UNIVERSITY The 2130 Arapahoe Avenue property in Boulder is currently one of the two campus locations of Naropa University, a private, nonprofit liberal arts institution. Inspired by Buddhist principles, Naropa integrates Eastern wisdom and the arts with Western scholarship, emphasizing a contemplative and holistic education. Naropa’s 2130 Arapahoe Campus

The following is excerpted from a recent letter from President Chuck Lief to the Naropa Community… After careful consideration and extensive deliberation, the President, Board of Trustees, and University Leadership have decided to sell the 2130 Arapahoe Campus. We recognize the profound value and importance that the land, which has been home to Naropa University for several decades, holds for many of us. We now need to balance that with the opportunity to create a significant fund for investment in Naropa’s future. The Arapahoe Campus is an asset we were fortunate to have purchased 40 years ago and can now leverage Sopher Sparn Architects LLC | 2505 Walnut Street, Suite 200 | Boulder, Colorado 80302 | 303.442.4422 4900-4402-9380, v. 2

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to ensure the long-term financial health and sustainability of Naropa. …We truly believe this is a decisive opportunity for Naropa University – one that we approach with both care and excitement, and that will allow us to envision the next 50 years. CHANGES AT NAROPA UNIVERSITY 2015 BOULDER VALLEY COMPREHENSIVE PLAN UPDATE In that time, Naropa has been a highly valued institution in Boulder community. During the 2015 major update to the BVCP, Naropa initiated and staff supported a request for a Land Use Map Change and Rezoning for this campus location. The initial consideration of the request was the then forthcoming University Master Plan, identifying the Comp Plan Policy (now) 5.19 – Diverse Workforce, Education and Training “to support the Boulder Valley School district as well as the variety of post-secondary educational institutions to offer quality continuing education…” 2015 Land Use Map

At that time, this campus’ Land Use designation was split; the majority being HR – High Density Residential, and the eastern ±20% being P – Public. In the Council Meeting packet dated October 13, 2016 (page 8), the staff recommended a map change specifically “…recognizes Naropa University as an important public institution.” And further (page 12) “…Acknowledging Naropa University as a Public use is consistent, on balance, with the BVCP.” Staff’s Analysis of the map change request identified that… “The requested (Public) land use reflects both the history of use on the property and the master plan for the site.” And further, “…staff recommends a designation of Public as it better aligns with the goals of the university and the long-term vision Naropa has for their Arapahoe Campus.” Staff at that time sighted Policy 8-10 Support for Community Facilities specifically to enable and support Naropa University as an Educational institution.” 2015 BVCP Updated Land Use Map

Conclusively then, the previous change to the Comp Plan adopted by Council changed Land Use for the site on the basis of the ongoing plan of Naropa University to occupy this site adjacent to CU, for Public purposes.

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The benefit to Naropa of Public Land Use and Zoning designations at that time was that it removed any limitations on floor area for educational purposes that Naropa might make. As is clear now, things change. NAROPA’S CURRENT CIRCUMSTANCE The ongoing needs of Naropa in this location – due to circumstances that could not have been foreseen at the time by Naropa University, city staff and indeed city leadership – are no longer tied to this location. The impacts of COVID-19 have had at times devasting effect on small liberal arts colleges across the country, as some 400 independent colleges around the country have closed since the pandemic. Naropa University has, in the wake of that circumstance, been adept in adjusting to new ways of learning and evolving student needs. Again, from then President Lief’s letter to the Naropa Community… Why now? With more than 40% of students (and a significant portion of staff and faculty) now operating primarily in hybrid and virtual spaces, we are redefining the very essence of what it means to be a community. This shift challenges us to reimagine the places and spaces needed to foster genuine connection, and to invest in innovative approaches to cultivate a sense of belonging and engagement in this new, hybrid world of academia. We remain committed to both the virtual and residential model, and the resources from the sale will allow for investment to strengthen each one. The University’s anticipated regrouping is clearly in aid of its long-term continuity in providing a model for liberal arts education in the Boulder community and beyond. That same identified 2015 BVCP Policy 8-10 Support for Community Facilities would suggest that support for Naropa University would need to take a different form today.

2. LAND USE MAP change to NEIGHBORHOOD 2 in Support of Higher Density Housing THE CITY’S NEED FOR HOUSING Naropa’s departure from this location presents the city with an opportunity to address the identified need for multi-family housing. And in this location in particular, the most appropriate type of housing is for students. CU CAMPUS MASTER PLAN 2021 – North Boulder Creek Campus Framework

The site sits at the northern perimeter of the University of Colorado and is clearly in an area identified by both the City and CU as a zone for future housing growth. It also sits at the current northern boundary of CU itself, along the southern face of Arapahoe Avenue. The area west of Naropa and south of Arapahoe is an amalgam of small businesses and multi-family housing, much of it, student oriented. It is important to note that, notwithstanding its Public zoning designation, the University of Colorado campus is not subject to City of Boulder zoning regulations and may develop at any density it deems appropriate. In this regard, the campus functions as a de facto enclave, beyond city control.

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CU’s PROPOSED NORTH BOULDER CREEK FRAMEWORK – BUILDING MASSING

Since CU does not necessarily abide by the city’s Land Use Code limitations on height or density, it is not clear how the RH-1 standards actually affects the redevelopment of the area south of Arapahoe when the University buys and develops the remaining privately owned RH-1 parcels.

3. CURRENT REQUEST: REZONING to RH-5 LIMITATIONS OF CURRENT PUBLIC ZONING DESIGNATION With the change of land use in this area from Public to Neighborhood 2 the city has rightly recognized that with Naropa leaving, the necessity for the previous support for such public uses is no longer needed. With the departure of Naropa from this site and their needs in mind for the sale of the property, as well as the city’s need for housing, particularly in this location, the Public Zone District no longer makes sense for this property. Specifically considering residential use on this site, while Public Zoning supports an unlimited floor area for any use other than residential, it allows a maximum of 6 dwelling units per acre for residential use. This is a significant underutilization of this property as a high density area adjacent to the University. CRITERIA FOR A REZONING OF THE PROPERTY With the now adopted Neighborhood 2 land use, the property will no longer be in compliance with the underlying Land Use Designation. Therefore, per the Criteria for Rezoning: …the city council shall grant a rezoning application only if the proposed rezoning is consistent with the policies and goals of the Boulder Valley Comprehensive Plan, and, for an application not incidental to a general revision of the zoning map, meets one of the following criteria: (1) The applicant demonstrates by clear and convincing evidence that the proposed rezoning is necessary to come into compliance with the Boulder Valley Comprehensive Plan map; (2) The existing zoning of the land was the result of a clerical error; (3) The existing zoning of the land was based on a mistake of fact; (4) The existing zoning of the land failed to take into account the constraints on development created by the natural characteristics of the land, including, but not limited to, steep slopes, floodplain, unstable soils and inadequate drainage; (5) The land or its surrounding environs has changed or is changing to such a degree that it is in the public interest to encourage a redevelopment of the area or to recognize the changed character of the area; or (6) The proposed rezoning is necessary in order to provide land for a community need that was not anticipated at the time of adoption of the Boulder Valley Comprehensive Plan. 4900-4402-9380, v. 2

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CONSISTENCY WITH BOULDER VALLEY COMPREHENSIVE PLAN POLICIES IN SUPPORT OF REZONING The following Policies and Goals from the current BVCP Update support the proposed rezoning to RH-5: Policy 55. Support for Redevelopment The city and county innovate and act to reduce fossil fuel consumption and greenhouse gas emissions to improve public health, strengthen community resilience and meet climate goals. The city will advance renewable energy generation and efficiency, sustainable transportation, sustainable land management and land planning practices that lower carbon emissions while supporting equity and economic vitality. Surrounding the campus with high density zoning The majority of the CU campus is today mostly surrounded by zoning districts with FARs greater than 1.0, and much of the surroundings have an FAR of 1.5 or greater. The intent of doing so was to congregate student housing areas adjacent to campus in clearly defined areas and thus limit their impact on single family residential neighborhoods. Allowing these greater density areas surrounding the campus incentivizes private development to target these zones for student housing projects, while maintaining the city’s purview via the Land Use Code, over the development of projects. Rezoning this land to RH-5 zoning designation keeps it generally consistent with adjacent RH-5 zones located to the east of the campus. There is probably no better place to put a significant number of housing units specifically designed for students than immediately adjacent to the CU Campus. Housing students here means that there is no carbon emissions for those students who would otherwise likely commute and require parking to access the campus. CITY ZONING MAP – High Density Zones Adjacent Campus

The site is also adjacent to major bus routes, a B-Cycle station, Lime Scooter Grove, and multiple bike paths. Additionally it is within a 15 minute walk to a major grocery store, regional shopping and multiple restaurants and amenities at the adjacent Boulder Valley Regional Center. To the west, it is a 15 minute walk to the Pearl Street Mall and the Downtown RTD Bus Station. Altogether, young people living here truly do not need a car to support their daily and weekly needs and support their off campus lives. Supporting a rezoning to RH-5 supports the redevelopment of this site and allows for this appropriate intensified student-oriented use and housing type in this location. Policy 24. Community Character and Evolution The city works with the community to shape how different areas evolve over time in varying ways and degrees. Change across the community will contribute to the unique and authentic character of different areas while supporting citywide goals.

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Protecting the single family character of Goss-Grove while recognizing the reality of the needs of CU About a dozen years ago, City Council modified the Land Use Code to protect the character of small, single family homes that still exist in much of the Goss-Grove Neighborhood north of Arapahoe. Over the years, many of the single family residences here have been converted into student housing, though some effort has gone into retaining this central Boulder area as a place where families could have a single family home near downtown. However the pressure on the neighborhood for student use continues to challenge that family ownership model. 2015/2020 BVCP Land Use Map

2025 BVCP Land Use Map

The city has acted to keep the character of Goss-Grove relatively intact, and to protect it from higher density student housing pushing into that neighborhood. This could explain why the neighborhood itself, has been left with relatively low allowable Floor Area Ratios (FAR), to minimize the impetus for larger student oriented projects from being developed there. But so long as there is a need for student housing, that pressure on Goss-Grove is not likely to end. Commensurate with this, the new Land Use Map identifies the area south of Neighborhood 2 – now limited to north of Marine – as University Land Use. The presumed intent is to use the Neighborhood 2 designated areas as a Transitional Area between the University and Goss-Grove Neighborhood 1 areas, thus protecting Neighborhood 1 areas, while clearly making a distinction between the boundary between them with higher density housing south of Arapahoe. Allowing supportive housing for students in appropriate locations Providing student housing at the Naropa campus can reduce the impetus for student rentals bleeding into the GossGrove Neighborhood to the north, thereby increasing the likelihood of retaining that single family occupant owned residential neighborhood intact. In fact, the city’s own growth potential and projections show that this is the area of town where the city expects to see the largest and most dense housing growth. This is due to the expected growth in the need for student housing and the preference on the part of the city to keep that dense growth close into the perimeter of CU, and on the campus itself. In keeping with that intention, Council rightly recognizing that the campus would likely continue to impact development in that area. The hope was however, that the campus impacts to Goss-Grove itself, could be limited, so that the family oriented neighborhood fabric – such that remained there – could remain intact. The proposal is in keeping with the areas of the city already intended and expected projections for higher housing densities and increases in population, per the 2015 Comp Plan update. As noted earlier in the discussion regarding the City’s identified location for the expected greatest increase in housing as identified in the map below.

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2015 BVCP – Additional Dwelling Unit Projections 2015-2014

The 2025 Major Update to the Comp Plan built upon that direction by reducing the intensity of the Land Use Designation in the area north of Arapahoe and increasing the potential intensity of supportable development to the south of Arapahoe. This is in keeping with the intent to recognize the difference in character of the areas north and south of Arapahoe. LAND USE TRANSITIONS – 2025 BVCP Diagram

While the Neighborhood 2 designation itself acts to make a transition to Goss-Grove from the University, the proposal to rezone the Naropa Campus to RH-5 with a mix of 3 & 4 story structures, acts to make a physical transition by virtue of its internal design. The project steps down in scale and provides substantial greenspace along the Arapahoe boundary, making the transition to the smaller scale structures to the north, while buffering the CU larger scale structures intended by the University, to the south. CU’s NORTH BOULDER CREEK FRAMEWORK – BUILDING MASSING

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As previously noted, CU does not necessarily abide by the Boulder Land Use Code’s limitations on mass and scale. CU’s plans for this area show substantially larger structures than the Neighborhood 2 designation would allow. RH-5 designation would act to allow the private development – limited by the city’s code – to meet that standard and thus provide a reasonable transition to Goss-Grove. ADDITIONAL RELEVENT 2025 COMP PLAN POLICIES While the above Policies have been addressed in depth, the following Policies are also supported through the rezoning of this property: Policy 25. Continued Use and Adaptive Reuse The city encourages the continued use and reuse of existing buildings for new purposes to recognize local history and architecture, activate vacant or under-utilized spaces, contribute to neighborhood activity and retain embodied carbon by reducing demolition and the creation of unnecessary building material waste. Multiple historic structures are being retained and reused as a part of the proposed project. This includes not only the already designated Lincoln School structure, but also two other residential scale structures are being relocated and raised above the floodplain and repurposed in support of the new use. Policy 27. Integrated Land Use and Transportation The city aligns land use and transportation planning to integrate a variety of neighborhoods with a range of uses

into a well-connected, safe, local and regional network of mobility choices. The city supports higher activity near multimodal corridors and transit centers that provide enhanced mobility choices and facilities. The city and county collaborate on transit investments and improvements so that local and regional transit systems are well integrated. As stated previously, much effort is going into making a residential facility that supports a highly pedestrian and bicycle oriented facility that is effectively located in supporting access of its residents to the CU campus. Policy 29. 15-Minute Neighborhoods The city encourages the evolution of “15-minute neighborhoods.” 15-minute neighborhoods are diverse, inclusive and connected areas in which services and amenities are easily and equitably accessible within 15 minutes from home for pedestrians of all abilities. The city encourages improvements that can enhance access to services and amenities, especially in areas that are currently underserved. As stated earlier, the site’s proximity to multiple supportive services and community centers makes this a effective 15-minute accessible residential facility. Policy 31. Historic, Archaeological and Cultural Resource Preservation The city and county identify, evaluate, designate, and steward historic places, archaeological resources, and cultural landscapes to connect the past with the future and support sustainability, equity and resilience. Preserving intangible cultural heritage such as traditions, practices, knowledge, and living relationships to place, elevating diverse stories that foster a shared sense of belonging and shaping how places change over time honors the full diversity of the Boulder Valley to help the community understand where it has been, where it is, and where it is going. Not only are the significant historic structures on the site being retained and repurposed, but a number of Boulders designated Champion Trees are identified and preserved and had a significant impact on the planning of buildings around them, maintaining their substantial impact on the environment of the project – and the neighborhood. Policy 37. Design Excellence for all Projects The city expects urban development and public places to be designed and built to achieve high standards of excellence. New public and private projects should respond to and enhance Boulder’s unique sense of place, including its natural resources and ecosystems, architectural character and significant historic and cultural resources. We believe, and we hope that the reviewing authorities will likewise come to the conclusion that the proposed project fulfills that intention – thru its planning and design, it’s respect for the environment and neighborhood, its use of materials, and its contribution to the values of the community. Policy 68. Social Infrastructure The city supports and encourages spaces, programs and institutions throughout the city that offer social places for interpersonal connections, belonging, well-being and community cohesion for people of all cultures, generations, 4900-4402-9380, v. 2

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incomes, backgrounds and abilities. The city recognizes the value of social infrastructure to build community resilience and wellness. The design of the new facility is intended to foster engagement of its residents, but also in the projects de facto support of the needs of Naropa University’s future financial stability, the rezoning furthers the city’s valuing of Naropa’s unique place in the community. Policy 73. Multimodal Transportation Strategy The city and county provide varied, reliable transportation choices to create an equitable, integrated and complete multimodal system that enables people who do not drive to fully participate in community life and access daily needs. The innovative planning, design, operation and maintenance of Boulder’s transportation system focuses on improving walking, rolling, bicycling, scooting, taking transit, riding micromobility and driving with a focus on moving people. The city and county collaborate to provide seamless connections between local and regional transportation facilities, programs and services, including trails, transit and Transportation Demand Management programs. As also stated earlier, thru the planning of the project and its creation of new significant access ways through the project to the University, the project significantly contributes to increasing mobility and safe methods of sustainably moving thru the city. Policy 90. Community Resources and Education The city and county will work collaboratively with community partners who provide vital arts, health, language access and cultural services as well as education on skills, trades and civic navigation to community members of the Boulder Valley. Naropa University is a community partner providing all of the cultural services and educational skills for its students. Naropa is making this change in their facilities in order to maintain its long term health and viability. The sale of this land, that they have been stewards of for 40 years, facilitates the institution’s future and financial sustainability in the Boulder community. In order to support this change in a longstanding community facility, the rezoning needs to occur so that they can maximize the return on their land sale. This, conveniently for the city and Naropa, is provided by the adjacent policy of addressing the housing needs for students adjacent to the university.

CONSISTENCY WITH SPECIFIC REZONING CRITERIA ABOVE (1) The applicant demonstrates by clear and convincing evidence that the proposed rezoning is necessary to come into compliance with the Boulder Valley Comprehensive Plan map; The current Public Zone Designation is no longer in compliance with the underlying land use. Consequentially the request to rezone the property to RH-5 is supportable in that context. BVCP 2025 MAJOR UPDATE – NEIGHBORHOOD 2 LAND USE DESIGNATION in support of REZONING to RH-5 This Land Use is broadly described in the Comp Plan as follows: 2025 BVCP NEIGHBORHOOD 2 CHARACTER SKETCH EXCERPT

What it is. Neighborhood 2 areas are primarily residential neighborhoods that feature a mix of denser housing types and larger buildings. Thoughtfully integrated commercial and other non-residential uses are generally concentrated near transit services.

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Why it matters. Neighborhood 2 provides opportunities for more people to live close to jobs, schools, parks, shops and mobility options. The additional density in these neighborhoods supports vibrant businesses and community spaces, supports the development of a robust transit network and fosters walkable urban neighborhoods. 2016 BVCP Adopted Land Use Map

Per the adopted map, the sites south of Goss Grove and north of the University are clearly intended as a buffer between the anticipated scale of the future redevelopment of the University south of Arapahoe (see also CU’s PROPOSED NORTH BOULDER CREEK FRAMEWORK diagram above). The RH-5 density of 1.5 FAR is supportable, as noted previously, to allow for a substantial level of housing adjacent to the CU campus and in keeping with the City’s Dwelling Unit Projections (pictured above) for this area south of Arapahoe. Having denser development of student housing in this area south of Arapahoe places density in that portion of the city where it is most useful for both residents and as a limiter of impacts to nearby single family neighborhoods. (5) The land or its surrounding environs has changed or is changing to such a degree that it is in the public interest to encourage a redevelopment of the area or to recognize the changed character of the area; With the adoption and implementation of University of Colorado Boulder’s Campus Master Plan 2021, which was made public after the Major Update to the Comp Plan of 2015, the surrounding context of the properties like this one on the edge of the campus is significantly altered. What has Changed… the City’s Land Use Map As noted previously, the city has now approved a change to the Land Use Map that formalizes the intention for greater density in the area south of Arapahoe by identifying the land there as either University or Neighborhood 2. Neighborhood 2 is by definition intended for higher intensity development than that of Neighborhood 1 north of Arapahoe. This is now a codified and established direction of the city’s long term vision for this area. Please note that Neighborhood 1 includes significant amounts of land zoned as RH-2, which allows up to a 1.07 FAR with Site Review – all north of Arapahoe. The proposed zoning of the 2130 Arapahoe site south of Arapahoe to RH-5 with a maximum of a 1.50 FAR is supportable, at the very least because it is in keeping with the differentiation between the two land use designations. The only other zone district in the new Neighborhood 2 land use in this area is RH-1, which only allows up to a .67 FAR. Rezoning 2130 to RH-1 would mean that the site would now have an allowable density less than what can occur in the area north of Arapahoe. This is not in keeping with the intent of the Neighborhood 2 designation.

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What is Changing… CU’s PROPOSED NORTH BOULDER CREEK FRAMEWORK – BUILDING MASSING

The framework pictured here shows that the direct impacts from the planned CU changes to the area requires significant rethinking to this area directly adjacent to the campus. The current Comp Plan Land Use Map has started to address this need by changing the designation of properties south of Arapahoe. And now applicant seeks to implement the intent of the 2025 BVCP pursuant to a rezone of the property to RH-5. The proposed housing (depicted in blue) on the 2130 Arapahoe site is completely in keeping with the current and anticipated changes with beginning implementation of the Plan with Residence One and the projected overall development by CU in this zone north of Boulder Creek. This change to the adjacent surroundings supports the rezoning per this criterion – as does the change to the Land Use designation itself. (6) The proposed rezoning is necessary in order to provide land for a community need that was not anticipated at the time of adoption of the Boulder Valley Comprehensive Plan. With the departure of Naropa from this site and their needs in mind for the sale of the property, as well as the city’s need for housing, particularly in this location, the Public Zone District no longer makes sense for this property, as it did at the time of the BVCP update in 2015, when it was thought that Naropa would remain at this location for the foreseeable future. RH-1 vs RH-5… a word on CU’s Residence 1 and the RH-1 Zoning District The RH-5 Zone designation is clearly the best way for the City to support adequate housing for students in this location. In the Planning Board’s Concept Plan Hearing on the topic, the question of rezoning to RH-1 instead of RH-5 was raised by a couple of board members. Consider the example of CU’s Residence 1. Residence 1 is currently under construction between 19th & 20th Streets at Athens Street. Portions of that site sit within the RH-1 zoning district. Our understanding of the plans for the construction of Residence One is as follows: • Two buildings, at least one of which is 7 stories. • +/- 330 students. • +/- 129,000SF. (per CU website) on +/- 1.98 acres (per Tec Doc application). • +/- 1.49 FAR (which is basically the 1.5 FAR allowed in RH-5). This is significantly greater than what the RH-1 zone, with a maximum FAR of 0.67, supports.

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Again… RH-1 allows a maximum FAR of 0.67, is now within the Neighborhood 2 Land Use. This allows barely more than RL-1, a low density zoning district that allows a maximum of .5 FAR. Meanwhile… RH-2 allows a maximum FAR of 1.07, is now within the Neighborhood 1 Land Use. This zone is found in Goss-Grove; arguably a lower intensity land use district that Neighborhood 2. In this context, it is difficult to understand how the RH-1 zone supports a Neighborhood 2 intention. Consequently, RH-1 would allow less density than is currently allowed in Goss Grove to the north. RESIDENCE ONE – Cleared Construction Site Aerial Site Overlaid on RH-1 & Public Zone

Pictured above is the cleared site prepared for the construction of CU’s building. To the right is the city’s zoning map with the building site outlined. This map clearly shows that the site and structure are significantly overlapping with the RH-1 zone.

In conclusion, the proposed rezoning of 2130 Arapahoe Avenue from Public to RH-5 reflects a necessary and timely response to the evolving needs of both Naropa University and the City of Boulder. With Naropa’s planned departure from the site and a demonstrated need for student housing adjacent to the University of Colorado campus, the current Public designation no longer serves a viable public purpose. A change to RH-5 not only aligns with the city’s long-standing planning goals and housing projections but also upholds the intent of protecting nearby single-family neighborhoods by concentrating student housing in more appropriate zones. This transition supports Naropa’s future, addresses community housing needs, and maintains consistency with the Boulder Valley Comprehensive Plan.

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