Attachment C - Equity and Engagement Plan

Attachment C: Equity and Engagement Plan Housing and Human Services staff conducted a Rapid Response Equity Assessment and developed a Public Engagement Plan for the recommended affordable housing impact fee. Staff intentionally chose to complete a Rapid Response Equity Assessment, as the scale and size of this potential policy change did not justify the use of the more complex Racial Equity Instrument. The Public Engagement Plan was informed by the city’s adopted Engagement Strategic Framework.

Rapid Response Equity Assessment

Boulder seeks a future with equitable access to health, prosperity and fulfillment that is not limited based on a person’s race, ethnicity, age, gender, ability, religion, sexuality, or socioeconomic status. This includes meeting community expectations for our core service delivery and ensuring that the root causes of inequities are eliminated through city policies, practices, programs, and financial decisions. City employees are encouraged to use the assessment within their teams who will influence decision-making. The four guiding questions below are applied to underrepresented groups, ensuring equity in decisions across age, race, ethnicity, gender, sexual orientation, socio-economic status and abilities.

1. What is the policy, activity or budget decision that could impact racial equity?

Demolitions and significant additions to single-unit dwellings in the city often remove smaller, relatively affordable homes and replace them with larger, more expensive homes. This type of development is not subject to the city’s existing Inclusionary Housing (“IH”) regulations. An impact fee would ensure that this type of development would contribute funds to address the affordable housing needs attributable to such development. The fee would ensure equity in how residential development and additions contribute to affordable housing in the community. Current program rules create incentives for demolition of smaller homes, which have typically been more affordable, to rebuild much larger and much more expensive homes. Reducing the number of smaller, more affordable homes in the city contributes to greater economic disparities among residents. The data collected by GG+A shows that new replacement or expanded single-unit homes are valued at significantly higher prices than smaller and older existing homes, not only due to larger living spaces, but also for a premium on new construction.

2. Who is or will be negatively impacted by the decision?

The intended goal of this change is to level the playing field for companies and households building or remodeling large homes within the city (current policy applies IH only to newly created housing units). While all policy changes come with unintended consequences, staff has made considerations and exemptions for smaller home remodels, as to not disproportionately impact community members with more modest incomes.

The burden of this policy change will be carried by those entities and homeowners redeveloping smaller, more affordable homes to larger, expensive homes. However, the development impact fee paid by these entities will directly contribute to the funding of additional affordable homes throughout the community. Based on research outlined in the Nexus Study, higher-income households within a local economy tend to result in an increase in personal consumption and spending. In turn, additional consumption and spending generates additional employment (jobs). This increase in jobs generates new workforce households and, in turn, the number of affordable units required to house them.

3. Who is or will experience benefits?

The City of Boulder actively works to maintain existing affordable homeownership and rental units and increase the stock of permanently affordable housing. Funds collected from a possible impact fee would be placed in the city’s affordable housing fund. Monies received into this fund are restricted solely for the construction, purchase, and maintenance of affordable housing and for the costs of administering programs related to affordable housing. Typically, residents of affordable housing in Boulder are more racially, ethnically, and economically diverse compared to the general population (Affordable Housing Data Dashboard). Residents of affordable housing in Boulder are also more diverse in their ability status. 1 Offering diverse housing options for all people is a core value of the Boulder Valley Comprehensive Plan. The potential development impact fee broadly supports this goal and the desired result of this impact fee, and any subsequent policy proposal, is to continue to support this mission. Housing stability is key to reducing intergenerational poverty and increasing economic mobility. Accessibility to quality affordable housing has been shown to improve quality of education, health and well-being, personal relationships, security, and financial outcomes.

The City’s Affordable Housing Program currently serves double the percentage of communities of color as compared to the percentage of the whole population, and therefore, it is reasonable to conclude that expanding funding for affordable housing within the City of Boulder will also serve a higher rate of communities of color than the market currently serves.

4. What strategies might mitigate or avoid unintended consequences for people of color?

The intent of this policy proposal is to mitigate gaps in the current Inclusionary Housing program. The IH program only applies to “new” residential development. Since remaining land appropriate for residential development within the city is limited, it is essential that a reasonable proportion of such land be developed into affordable housing units. This is

City of Boulder, Boulder County, City and County of Broomfield, City of Longmont: Draft 2020-2024 Consolidated Plan for Housing and Community Development, page 53. 1

particularly true because, in the absence of interventions, available land is often developed with large expensive housing, which both reduces opportunities for more affordable housing and contributes to a general rise in prices for all housing in the community. By creating a development impact fee to address single unit home replacements and large additions, this change aims to ensure equity in how residential development and additions contribute to affordable housing in the community. In evaluating alternatives staff has carefully considered how different program details, such as minimum square foot thresholds and allowances for ADUs, can be used to avoid unintended consequences for underrepresented groups, ensuring equity across age, race, ethnicity, gender, sexual orientation, socio-economic status and abilities.

Public Engagement Plan

Boulder’s affordable housing programs have evolved over the last 30 years. Figure 1 below outlines the nine steps to good community engagement. Step 9 “Reflect and evaluate” has led to this Nexus Study and potential code changes, which aims for the program to apply development fees across several different types of housing development.

Figure 1: 9 Steps to Good Engagement, Engagement Strategic Framework (p. 9). Step 1: Define the issue before embarking. Desired Outcome: Address shortcomings in the current Inclusionary Housing program to ensure equity in how residential development and redevelopment contribute to affordable housing in the community.

Step 2: Determine who is affected. Primary Stakeholders: Market-rate housing developers and homeowners. Secondary Stakeholders: Contractors and design professionals for single unit development and all residents of the city. Housing affordability has long been a significant challenge facing Boulder. Households that find housing costs burdensome, or by the combined costs of housing and transportation, have less money available for other necessities, and may find it difficult to actively participate in the community. This leads to a more transient and less stable workforce, a less culturally and socioeconomically diverse community, additional demands on supportive human services, and the exclusion of key community members from civic affairs. Continued escalation of housing costs has disproportionately impacted low- and moderate-income households. Important Sources of Input: 1. City of Boulder Technical Advisory Group (HHS) 2. City of Boulder Housing Advisory Board (HHS) 3. City of Boulder Planning Board (PB) Secondary Sources of Input: 1. Market-rate homeownership developers. 2. Housing professionals, including architects, planning consultants, general contractors, lenders, design professionals, and realtors. 3. Community members. Step 3. Create a public engagement plan. Level of Engagement. Based on the technical nature of the desired outcome, the project team has structured public engagement as follows:

Participation Goal

Parties

Inform General public

Provide with balanced and objective information to assist them in understanding a problem, alternatives, opportunities and/or solutions

Promise

We will keep you informed.

Consult Market-rate homeownership developers Housing professionals Contacts (owners, contractors, design professionals) listed on a permit for a home addition within the last three years Other city departments with resources Obtain feedback on consultant analysis and recommendations.

Involve Technical Advisory Group Housing Advisory Board Planning Board City Council

Collaborate

Work throughout the process to ensure that concerns and aspirations are consistently understood and considered.

Partner with, in each aspect of decision, including development of alternatives and identification of preferred solution.

We will keep you informed, listen to you, and acknowledge your concerns and aspirations, and share feedback on how public input influenced the decision. We will seek your feedback on drafts and proposals.

We will work with you to ensure that your concerns and aspirations are reflected in any alternatives and share feedback on how the input influenced the decision.

We will work together with you to formulate solutions and to incorporate your advice and recommendations into the decisions to the maximum extent possible.

Step 4. Share a foundation of knowledge. In progress. Information sharing has been done via the following channels: • The Housing Advisory Board, Planning Board, and City Council memos and presentations in the spring of 2025 provided the initial foundation of knowledge of the Nexus Study’s findings. •

A city project website has been published since Oct. 2024.

•

Updates have been provided in HHS and PD&S department newsletters.

•

An engagement site was published in late June via the Be Heard Boulder platform.

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An email containing information and soliciting feedback was sent directly to contacts (owners, contractors, design professionals) listed on a permit for a home addition within the last three years.

•

An email was sent directly to HHS contacts on Aug. 22.

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Staff raised awareness and shared information on the project at the city’s “What’s Up Boulder” event on Sep. 7, 2025.

Step 5. Identify options. In progress. Staff has been considering public input to understand concerns and aspirations on the impact fee and to develop alternatives. Staff will continue to examine how different program details, such as minimum square foot thresholds and allowances for minor additions and ADUs, should be defined to avoid unintended consequences for underrepresented groups, ensuring equity across age, race, ethnicity, gender, sexual orientation, socio-economic status and abilities. Step 6. Evaluate options. In progress. The public's input has been used to develop staff recommendations and evaluate program details for the impact fee. Staff will continue to evaluate whether the alternatives and options reflect public concerns and aspirations. As the project progresses, staff, boards, and council will consider the trade-offs of different options, understanding that there may be competing needs and priorities. Meetings were held with the Housing Advisory Board on Aug. 27 and Planning Board on Sep. 2, 2025. City Council consideration is scheduled for Oct. 16 (first reading) and Nov. 6, 2025 (second reading) to consider the code changes necessary to add the recommended impact fee. Steps 7. Make a Decision In progress. A decision on the impact fee will be made by City Council at public hearing. Public input will be considered by council, both formal comments made prior to the hearing and testimony given at the hearing.

Step 8. Communicate Decision and Rationale In progress. Step 9. Reflect and Evaluate In progress.