Attachment B - Area III PR CNA Staff Response to PB Questions

January 20, 2026 Planning Board Public Hearing Item #2: Consideration of a motion to determine if there is sufficient community need as defined in the Boulder Valley Comprehensive Plan to warrant further consideration of a Service Area Expansion Plan for the Area IIIPlanning Reserve. Staff Response to Laura Kaplan Questions I appreciate the information and am glad to hear that Parks is developing additional indicators that take into account (among other things) proximity to Open Space, given that our 45,000 acres of Open Space and its 155 miles of trails are not included in the current Level of Service acreage analysis. Across the country, urban parkland Levels of Service (LOS) do not consider proximity to or quantity of nearby natural lands, regardless of who owns or operates them because thriving communities need both passive and active recreation. Both types of activity support a healthy city, but key distinctions mean they are measured separately. Boulder’s Open Space and Mountain Parks (OSMP) system is unique in that it is provided by the city. Natural land systems intended for conservation, agriculture, and/or passive recreation exist all over the country, however, are more often provided by counties, states, the federal government, and non-profit conservation organizations. Boulder’s open space system was originally designed to conserve land for wildlife and passive recreation and to serve as a buffer between Boulder and nearby development. While most of OSMP-managed lands are open to the public (with some areas requiring off-trail permits and/or subject to seasonal wildlife closures), Boulder’s Charter limits human use of OSMP lands to agricultural and passive recreation purposes (e.g. hiking, running, birdwatching, photography and where designated horseback riding, fishing and biking). The Charter also states that OSMP land may not be improved after acquisition unless such improvements are necessary to protect or maintain the land or to provide for passive recreational, open agricultural, or wildlife habitat use of the land. Importantly, OSMP lands cannot host competitive events. This means that amenities like a dog park, tennis courts, and a recreation center are not currently possible on OSMP lands, nor are activities like a cross-country race, a soccer tournament, or tennis lessons. Boulder’s well-planned urban parks system is designed to promote close-to-home health and wellbeing while building social capital. Levels of Service for Urban Parks nationally and in Boulder consider all the urban parkland land for more active recreation along with the ability to develop supporting facilities and amenities. Based upon analysis for the 2022 BPR Plan, the city must develop all currently owned parkland, including land in the Planning Reserve, to maintain the existing Level of Service for the Boulder community based on population estimates for 2040.

Could staff also please provide information about the purchase of the 189-acre parcel in the Planning Reserve? Specifically, what year was the purchase, what was the purchase price, what sources of funding contributed in what amounts, and any ordinance, legal document, agreement, or policy that specifies the future use of the parcel. The city and the Boulder Municipal Property Authority (BMPA) purchased the Planning Reserve park site in 1999. BMPA is often used as a funding agency for the purchase of land for the benefit of the City. Staff would need additional time to research the purchase price, as the Planning Reserve park site was assembled through several purchases. The city purchased the property in the late 1990s with funds from a 0.25 sales and use tax and bonding measure that was approved by voters in 1995. The short title from the ballot measure of Ordinance 5740 provides that the funds are to be used, in part, for park land acquisition. There are no additional limitations on the disposition of land in the ballot measure, or the 1998 amendments to the ballot measure in Ordinance 5999. Further, there are no outstanding bond commitments from the 1995 ballot measure, so in turn, no bond covenants that would encumber the property. “Park land," “park property," and "recreation facilities"” are defined in Boulder Charter § 154 as “all lands donated to the city for park or recreation purposes, acquired by the city through purchase, dedication, deed, or condemnation for park or recreation purposes, or purchased or improved in whole or in part with funds from the permanent park and recreation fund.” If the city wanted to use these lands for uses other than parks and recreation purposes, it would need to follow the procedures in the city charter related to the disposition of park land. Boulder Charter § 162 provides that “park lands may be disposed of by the city council, but only upon the affirmative vote of at least four members of the parks and recreation advisory board. An advisory recommendation, which shall not be binding on the council, shall be obtained from the planning board prior to the disposition or lease of park lands.” Additionally, because the land was purchased using proceeds from a sales and use tax and bonding measure that was primarily for the acquisition of park land for active and recreational uses, a change in how that land is used would require a process to determine how and how much payment must be refunded. Other considerations related to this site include: •

Following the approval of the ballot item, a site selection process was initiated and ultimately the city purchased the Valmont Park site and Area III-Planning Reserve land. The Planning Reserve site was prioritized because of its large expanse of land that would allow a comprehensive park with a variety of amenities together and serve a broad cross section of the community with flexible, multiple use facilities. Since the original planning and purchase 30 years ago, the Planning Reserve site has always been dedicated as a critical location for the city to expand its portfolio of parks and recreation assets to meet community needs and parks levels of service.

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By design and classification, city and regional parks serve the entire community, as well as the surrounding county, and draw visitors to Boulder. Regional parks are generally large tracts of land that provide space for high-intensity recreational activities, as well as natural areas set aside for their scenic qualities and passive recreational opportunities. Valmont City Park, with 173 acres, is the only example of a large urban park in Boulder. The Boulder Reservoir is the only regional park operated by BPR and provides a mix of developed and natural areas that attract visitors from well outside the city limits.

1. Staff's analysis says "Based on staff modeling of the existing Comprehensive Plan land use map, there is surplus capacity within the Service Area to accommodate more than 10,000 additional housing units. There is also capacity to accommodate more than 10,000 additional housing units when existing zoning is modeled, even when only focused on locations within ½ mile from a transit corridor." Can you share this modeling with us? In each of these cases (land use map and zoning within 1/2 mile from transit corridors), where are you seeing the 10K units being built? Staff perform analyses to determine the potential theoretical capacity for housing and other uses as a regular part of planning efforts such as area and subcommunity plans, in response to state legislation like the Transit Oriented Communities bill (HB24-1313), and as part of the Boulder Valley Comprehensive Plan update. The 2015 Future Land Use map modeling examined the potential dwelling unit capacity of the future land use designations within the service area applying the following criteria: • • • • •

Average density based on the composition of zoning districts within each land use designation Average mix of residential types and non-residential uses for each land use Average unit sizes for different residential types, e.g. single-unit, multi-unit, etc. Development capacity reduction for flood constraints and on-site open space Developed at 75% of land use capacity after development capacity reductions

The outcome of the land use modeling confirms that under the current 2015 Comprehensive Plan future land use map, there is capacity for more than 10,000 units. Staff are continuing to model the potential of the new proposed future land use framework and more information will be available as part of the draft review in March. Staff have also examined potential capacity by analyzing existing zoning in the city. Potential zoning capacity represents a reasonable calculation of growth based on observed densities of typical redevelopment scenarios and other assumptions. Recently, staff analyzed properties that met the following criteria to estimate potential redevelopment capacity: • •

Within ½ mile of a transit corridor Currently a non-residential use

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At least 1 acre in size 25–50-year-old primary building Developed at 50% or less based on current zoning allowances

The outcome of this scenario identified 50 properties, which staff considered the most reasonable as it limited the number of redevelopment sites and identified those sites that may have the greatest likelihood of changing in the future, and resulted in a potential zoning capacity estimate of an additional approximately 6,700 housing units. However, minor adjustments to the redevelopment criteria, such as adding parcels smaller than 1 acre or including properties that are developed at more than 50% of current zoning allowance, led to substantial increases to zoning capacity with estimates as high as an additional 40,000 or more units. This zoning analysis was also performed prior to recent updates like the Family-friendly Vibrant Neighborhoods ordinance that expanded zoning capacity in certain areas of the city. Note, both of these analyses are based on many assumptions and should be considered with some caution as it is impossible to determine capacity with absolute certainty. Note, too, the important consideration that this estimates a theoretical “build-out” capacity, not a likely scenario projection, and that the rate and likelihood of properties being redeveloped in this matter are influenced by individual property ownership preferences, overall market conditions, public sentiment, practical logistical limitations for providing additional public services, and demographic shifts. 2. Staff's analysis says "It would take a significant amount of time to develop new units and will partly depend on market forces." I understand that it's impossible to predict the future and I appreciate the challenges of trying to do so. However, if we just look at past trends and the current rates of development, about how many years would it take to reach 10K new units, and what mix of housing types could be expected? Are we looking at mostly large apartment and condo buildings? Staff did not perform a specific analysis on housing types as that wasn’t part of determining whether additional land is needed to address the housing shortage goal identified by DRCOG (approximately 9500 units). As far as the time it would take to achieve that goal, it is really difficult to estimate as it depends on many factors that are outside the city’s control like market demand, interest rates, labor availability, overall economic health, etc. Historically, the city has permitted approximately 400 units per year on average, so that could indicate it may take upwards of 25 years to develop that much housing. However, there have been several policy and zoning changes made recently, or that are currently in the works, to create greater flexibility for a variety of residential uses and help make project reviews more effective and efficient, so it is very possible that annual approvals could increase over time. 3. I did not see an analysis of the need specifically for middle housing types or middle- income affordable units. One reason that folks have argued for opening the planning reserve at this

time is that it may be the city's best opportunity to gain missing middle housing types and/or middle income permanently affordable units that are so difficult to obtain in Area I. It has been suggested that this could be achieved through some combination of use of city-owned land (including the 189-acre parcel in addition to the 30-acre parcel) and/or annexation agreements. What are the prospects for attaining middle housing types and middle-income affordable units within the service area vs. area III? Staff have not analyzed or pre-determined what types of uses would be most appropriate in the Planning Reserve as that is something to be addressed through a future Service Area Expansion Plan. Most of the city-owned land is dedicated for park uses and development in the Planning Reserve will primarily occur on private land. Annexation agreements provide an opportunity to leverage affordable housing contributions above and beyond our standard Inclusionary Housing requirements and could conceptually include expectations around middle housing. It should be noted however that newly developed middle housing types are rarely affordable for middle income households to buy since homebuyers are willing to pay a premium for new construction. Therefore, while the Planning Reserve may yield more missing middle housing types, staff cautions against assuming that the Planning Reserve will yield significantly more middle-income housing. A challenge presented by the Planning Reserve in comparison to the existing Service Area is that there is no infrastructure in place. Substantial market rate development will be required to fund infrastructure improvements where those funds might otherwise have been available to subsidize higher levels of affordable housing if infrastructure was already in place. As an example, the 30acre parcel overseen by Housing & Human Services would require some market rate housing to help subsidize the affordable homes and even more to pay for the infrastructure upgrades needed to service the area. It would be financially infeasible for that property to be entirely affordable, or even middle-income. 4. Related to #3, what is the city's power to compel development of middle housing types and middle-income affordable units through the Area III process? Do we have the legal ability, through the comp plan, to get different outcomes (in terms of housing types and affordable units) in Area III vs. a typical Area II annexation? I'm thinking here about the policy we just saw in the Comp Plan 1.17(c) where properties that were moved east of the blue line had unique development restrictions placed upon them via the Comp Plan. Using that as a model, could there be a new Comp Plan policy that directs a higher level of middle housing types or middleincome affordability for properties annexed from Area III (or some similar mechanism) to direct future development of Planning Reserve parcels to meet that community need? The Service Area Expansion Plan could include more direct policy language to guide future annexations within this area and the types of preferred, or even required, uses. However, staff recommend caution with requiring specific uses as many uncontrollable market forces and events

can significantly influence the feasibility of specific outcomes. It is also worth noting that the types of outcomes the city would like to see can also change over time. Staff do not recommend including policies in the Comprehensive Plan that specifically reference or limit the types of uses that can be considered for the Planning Reserve as that would be more appropriate to address through the Service Area Expansion Plan. 5. Related to #4, could staff please remind us how the Area III initiation process relates to annexation agreements? My rough understanding is that if PB and CC vote to proceed to the next step, staff would at a later date initiate a service area expansion plan, which is similar to an area plan or subcommunity plan. I assume that at some point, Planning Reserve lands in Area III would be moved to Area II, and I'm guessing that would happen in conjunction with adopting the service area expansion plan - but please correct me if I'm wrong! Is there any ability through that process to ensure that we would get different, creative outcomes from annexation of private property in Area III? Or would Area III properties just become like any other Area II property, legally speaking? Any change from Area III-Planning Reserve to Area II may only occur after, or concurrent with, adoption of a Service Area Expansion Plan (often casually referred to as “Step 3”). The Expansion Plan would guide the phasing of expansion and identify if a portion or all of the Planning Reserve should be changed from Area III to Area II. Area II properties in this location would be treated the same as other Area II lands. However, the goals and policies of the Service Area Expansion Plan would guide annexation agreements and could influence desired outcomes , . As is currently the case, annexations would be initiated generally by private property owners and will need to meet annexation criteria at that time, including the requirement for 1/6 contiguity to existing city limits. 6. Finally, if there is interest in pursuing a disposal process for the 189 acre city parcel (or part of it) to enable housing to be built there, how and when would that decision be made, and how would that process take place in conjunction with the preparation of the service area expansion plan? (This is assuming that using this parcel for housing could be part of the justification for opening the Planning Reserve). Initiation of a Service Area Expansion Plan process is a city decision (Planning Board and City Council) whereas adoption of the Expansion Plan is a city and county decision which includes the four Boulder Valley Comprehensive Plan adopting bodies (City Council, Planning Board, the Boulder County Planning Commission and the Board of County Commissioners). The Service Area Expansion Plan would evaluate options and determine the goals and policies for development of the Planning Reserve. If the Expansion Plan included direction to repurpose a portion, or all, of the park land for alternative uses, then a disposal process would be an implementation step initiated after adoption of the Expansion Plan.

7. Some folks have compared the Planning Reserve to an opportunity like Holiday, to master plan something creative and special. Could you please provide some background on Holiday's development and why the city was able to do master planning there, and how that compares to the Area III Planning Reserve? I do note that the City was the owner of the property, per this case study, but were there any other factors that contributed to our ability to do master planning there? The city purchased the 30-acre Holiday property after the drive-in closed in the early 1990s. It was then annexed and sold to Boulder Housing Partners (BHP). This annexation allowed for more flexibility to determine uses on the site, and the area was under the control of one lead developer, BHP, which enabled a singular implementation of the North Boulder Subcommunity Plan’s vision for the area. New zoning districts (i.e., RMX-2 and MU-1) were created to implement the North Boulder Subcommunity Plan and are largely unique to the Holiday development. RMX-2 is a unique zone in that it has a special density bonus section based on the proposed amount of affordability. It also requires a diversity of housing types based on site size (e.g., the larger the site, the more housing types that are required). The approved Holiday Site Review included a collection of different typologies at different scales and characters each with different design guidelines and street sections. The construction drawings and permits that followed Site Review were then reviewed against those guidelines. The Armory development, which is in the same area but technically fell under a separate Site Review and development process, was implemented in a very similar manner to the overall Holiday development. The large Holiday site being under one lead developer enabled effective implementation of the Plan while also achieving architectural diversity through use of different builders. The Area III-Planning Reserve site is likely to follow a similar planning process as that of Holiday and other planned areas, but the implementation will likely be more like that of other general locations around the city, where a design vision and standards are realized in a variety of ways. Area III is fundamentally different than the Holiday site in that it has significantly more individual property owners, and it is unclear if these owners would be willing to redevelop or sell to a consolidated ownership entity.

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