April 2, 2019
Dear City Council,
The Peoples League for Action Now (PLAN-Boulder County) supports the goals established as
the basis for the Opportunity Zone moratorium and as restated on page one of the staff memo for
item 6A.

However, the memo first appeared on the City’s website this past Friday evening which did not
leave enough time for the Community’s stakeholders to evaluate the proposed changes and
understand their far reaching repercussions. Consequently, neither PLAN nor the Community at
large is able to make informed decisions to support or oppose the specific use table changes
proposed in the memo. Moreover, if Council allows every change to Use Standards proposed for
the OZ to be applied citywide as the memo proposes, potentially ill-considered decision for the
OZ will then be perpetuated citywide.
We urge that Council NOT direct staff to proceed with the proposed changes yet, and instead,
defer direction on the specifics until a reasonable community feedback period has been

It appears that lifting the moratorium as quickly as possible has become the focus of the OZ
process moratorium rather than developing an overall vision for the future of the area. This is
the opposite of planning, as are lifting the moratorium zone by zone as changes are completed
rather than taking a holistic approach, and the citywide application of Use Standard changes
adopted for the OZ.
The Opportunity Zone contains the largest areas left in Boulder that could be transformed by
new development, and staff correctly points out that it should allow us to achieve more housing

The OZ offers investors and developers a financial windfall that justifies the capture of greater
benefits by the Community for permanently affordable housing and commercial space. Far
greater percentages of permanently affordable housing than the Inclusionary Housing program’s
25% mandate should be required, and every unit should be built on-site. The memo’s proposed
“incentives” to developers to provide certain community benefits disregards the value inherent in
the OZ and seemingly, seeks to ensure that investors, rather than the Community, reap the
maximum advantage from the OZ. But it is the Community, as the taxpayers footing the bill for
OZ tax exemptions, that should reap the maximum benefit.

Given such short notice, PLAN has not had time to conduct an analysis of the specific Use
Standard changes. However, a cursory examination identifies some representative elements that
warrant more careful consideration as to whether they represent an approach that serves the
needs of our Community:

 Efficiency Units are not inherently affordable, and they do not serve families with
affordable housing needs. The units in the 3303 Broadway proposal from a few years
ago were some of the highest price per square foot units in the City.

 Does a proliferation of convenience stores incentivize retail in business and industrial
areas, and does the existence of a convenience store constitute a 15 minute walkable

 Does removing “personal service uses” from Manufactured Housing zones preserve those
communities or deny their residents much need income generation options?

PLAN urges Council to enable a reasonable community feedback period on the proposals
contained in the memo BEFORE directing staff how to proceed with the proposed measures.

Respectfully, PLAN-Boulder County