Attachment A - Area III PR CNA County Referral Response

Community Planning & Permitting Courthouse Annex • 2045 13th Street • Boulder, Colorado 80302 Mailing Address: P.O. Box 471 • Boulder, Colorado 80306 303-441-3930 • www.BoulderCounty.gov

TO: FROM: RE: DATE:

Kristofer Johnson, Comprehensive Planning Manager Hannah Hippely, Long Range Planning Division Manager Community Needs Related to Area III-Planning Reserve January 7, 2026

The county appreciates the opportunity to comment on the draft needs assessment memo prepared by city staff as part of the service area expansion process for the Area III Planning Reserve. The decision to initiate a service area expansion plan is a city only decision and we appreciate the consideration of these comments as part of that deliberation. At this time, it does not appear that the identified needs are of sufficient priority to initiate a Service Area expansion plan. If the identified needs are of sufficient priority to initiate a service area expansion plan is determined based on the criteria found in the amendment procedures of the Boulder Valley Comprehensive Development Plan Intergovernmental Agreement. These criteria include: a. Community Value: Expansion will address a long-term community value as articulated in the Comprehensive Plan. b. Capacity: The need for a service area expansion cannot be met within the existing Service Area because there is not suitable existing or potential land/service capacity. c. Benefit: Expansion will benefit the existing residents in the Boulder Valley and will have a lasting benefit for future generations. The identified community needs in the draft memo are: • approximately 9,500 additional housing units by 2032, • a new fire-rescue storage facility for reserve engines and equipment, • affordable Assisted Living Facility / Assisted Living options certified for Medicaid, • regional park to meet Level of Service standards for 2040 population projections, • small-scale farming options for local producers, • renewable energy generation to support the city’s move to zero-emission electricity with an increased emphasis on infrastructure resilience and transitions away from fossil fuel. Each expressed need does appear to align ideologically with an expressed community value and can meet criterion a when considered in that way. Decision makers may also want to

Claire Levy County Commissioner

Marta Loachamin County Commissioner

Ashley Stolzmann County Commissioner

consider how strongly linked the identified need is to the outcomes of the associated value. For example, how critical is the fire-rescue storage facility to the city being safe and responsibly governed? Each identified need is also examined against the capacity criterion b; the ability for the identified need to be met within the existing service area. Without access to the analysis, we cannot comment on the conclusions in the memo and for the purposes of this referral accept them at face value. Needed housing, fire-rescue storage facility, and assisted living options are all able to be located within the existing service area and do not meet this criterion. The current Boulder Valley Comprehensive Plan process underway should help define the community vision around where these needs should be located within the service area. Utility scale renewable energy and agricultural operations were found to meet criterion b, not able to be located within the existing service area. Utility scale renewable energy projects are often developed in rural areas without the benefit of urban facilities and services. Agricultural activity also typically does not require urban services and facilities. It does not seem necessary to plan for the extension of services for uses that do not require them and only seems reasonable to consider a service area expansion when there are needs that require services to be provided. The incapacity for a regional park to be located within the service area is not clear. The ability to locate this within the service area and the needs for services should be better understood before initiating a service area expansion for this purpose. Decision makers may want to consider if land and service availability, obstacles that can be addressed by service area expansion, are a primary impediment to the stated need. For example, the Area III Rural Preservation area is specifically intended to preserve lands for agricultural uses and the City of Boulder owns and manages the majority of the agricultural land in Area III. For the small-scale farming needs that cannot be accommodated within the existing service area the city may consider increasing access to city owned and managed agricultural lands in Area III for small producers. This need could be addressed through changes in land management practices and without changes to the Planning Reserve. Another example is that current Medicaid reimbursement rules impact the ability of organizations to provide these options more significantly than land availability. Having more land available through changes in the Planning Reserve will not change this underlying cost structure. In considering if the expansion of services benefits the existing residents of the Boulder Valley and if it would have a lasting benefit for future generations, it is found to not benefit existing residents due to the timeline of development, but that future generations may benefit once the development is complete. Unless there are significant shifts in how the 2

physical development of land occurs this is likely be the conclusion for many needs and it may be impossible for any need to meet this criterion. After review of the provided memo, we conclude that the identified needs, neither collectively nor individually, meet the criteria and necessitate the initiation of a service area expansion plan. Should the city find sufficient need to initiate a service area expansion plan we look forward to continued collaboration in the development of that plan.

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