PLAN-Boulder County commends the gestures toward low energy use in the proposed Baseline Zero project, but we have a number of concerns with the overall concept of the plans. We’d also like to emphasize that granting modifications to height and zoning requirements should not be a routine process, and it gives the city the right to press for a project that meets the city and neighborhood needs, which we do not think the current concept plan does.

BC-2 Zoning is intended for Community-oriented business. The concept proposal is for a hotel and for class-A office space, both of which would primarily serve metropolitan regional demands, not those of the surrounding community. Commuting access to the office space and guest access to the hotel would inevitably increase the city’s carbon footprint beyond any advantages achieved by a green building design.

The requested modifications to height requirements to 55 feet actually significantly understate the visual impact on the neighborhood, since the drawings on page 8 of the concept plan show the additional appurtenances approaching 70 feet. The entire massive nature of the buildings would significantly degrade the walkability and livability of the neighborhood. The Boulder Valley Comprehensive Plan states clearly (and we think appropriately) in Section 2.13 that “the character and livability of established residential neighborhoods will not be undermined by spill-over impacts from adjacent regional or community business zones or by incremental expansion of business activities into residential areas.”

In general, PLAN-Boulder County is strongly in favor of reducing parking space requirements to encourage alternate-mode transportation. However, this must be done with context in mind. The streets around the proposed development already suffer from spill-over parking from Brookside apartments and from CU. There is every reason to believe that both the office space and hotel would be served primarily by single-occupant vehicles and that parking would spill over into the neighborhood.

The greatest impact of the development as presented in the concept plan would be on traffic. Access would be primarily through two intersections that are already seriously overloaded, especially during rush hours undefined Baseline and 27th Way and Moorhead and 27th Way. Adding hundreds of vehicles for the commute is a bad idea, and we have already approved development that will increase congestion, since the High-Mar complex on Moorhead is under development. Moreover, cut-through traffic will be generated by commuters to and from the office space trying to avoid the overused intersections, which will affect local streets.

Again, the Boulder Valley Comprehensive Plan is clear on the transportation impact of new developments (Section 6.08): “Traffic impacts from a proposed development that cause unacceptable community or environmental impacts or unacceptable reduction in level of service will be mitigated.” The concept plan would clearly result in unacceptable impacts, but does not propose any mitigation. Genuine mitigation would be difficult to achieve in this location.

In summary, PLAN-Boulder County is not against development in this location, but it should follow the clear intent of the Boulder Valley Comprehensive plan and the zoning. Instead, this proposal is for increased in-commuting and traffic congestion in the area and would remove retail that currently serves the community and replace it with high-end office space and a hotel that would make the surrounding community less livable. The developer has owned this property for approximately five years, so degradation of the retail properties is largely attributable to deliberate withdrawal of leases. Development should meet the purposes of BC-2 zoning, rather than subverting them.

For PLAN-Boulder County, Raymond Bridge, Co-chair