To the Members of the Boulder City Council:

The intent of the procedure for the expansion of the Area II-Service Area into the Area III-Planning Reserve is to ensure that decisions about changes to the Service Area are based on Comprehensive Plan policies and city and/or county-initiated changes, rather than being “incremental, reactive, and applicant-driven”undefined as the City of Boulder and the County of Boulder agreed at the conclusion of the Area III Planning Project in 1993 that the process had become.

As you know, such an extension of the Area II-Service Area first requires the development of a Service Area Expansion Plan, which, among other elements, involves:

  • identification by staff and community of a range of community needs, and four-body approval
  • a determination of whether these needs can or cannot be met within the existing Service Area, and
  • zoning and planning of needed streets and utilities if the Service Area is to be enlarged.

Regrettably, the proposals currently before you for a professional sports training complex on Dr.Villavicencio’s property and for a housing and truck gardening project on the Palmos’ property are exactly what the current procedure was intended to prevent.

1.      The proposals are indeed “application-driven” and “reactive.” These proposals were initiated either at the instigation of the property owner or in close cooperation with the property owner based on needs purported by the applicants themselves. They were pointedly NOT initiated by and from the community.

2.      The proposals are indeed “incremental.” They do not deal with the Planning Reserve as a whole, but only with the individual properties owned or to be owned by the applicants. One of the major purposes of the Area III-Planning Reserve process is to assure that a coherent plan for the entire area is developed before any single property within it. Assuming for the sake of argument that the community determines that it needs a professional sports training complex or a housing and truck-gardening complex, and that those projects could not be developed within the existing Service Area, then many questions remain:

  • Where within the Planning Reserve would the best location for such facilities be?
  • How would these two projects affect what would subsequently be developed in the Planning Reserve?
  • Where would the roads and utilities be located?
  • How would the entire Planning Reserve be zoned?
  • What would happen to the city-owned land, which constitutes close to half of the property in the Planning Reserve? Would it still be appropriate for a park? If so, would it be in the best location for a park? Should it be exchanged for some of the private land in the Planning Reserve, and, if so, which private land?

Clearly, a lot of questions must be answered before any decisions can be reached about the current proposals. At the moment, you have gotten “the cart before the horse.” A sound public process for the possible expansion of the Area II-Service Area into the Area III-Planning Reserve would first need to be followed. Only after it has been implemented would the City of Boulder, the County of Boulder, the City Planning Board, and the County Planning Commission be in a position to consider any particular proposals.

The existing process has been attacked on the grounds that “community needs” may be very hard to ascertain. That is a reasonable concern. We do not pretend to know at this point exactly how they should be established. But we do know that they should be based only on a clear and broad community consensus, perhaps discerned from surveys, focus groups, and careful interviews with representatives of various segments of the community undefined and not by the clamor of any particular property owner or interest group.

It has also been criticized for inadvertently encouraging property owners to submit proposals which are destined to be automatically rejected, thereby causing unnecessary effort and expense. That critique also contains some validity and suggests that adjustments to the process would be appropriate, provided that its underlying intent is maintained.

Of the three options presented in the staff memo for this study session, PLAN-Boulder County supports Option 3: evaluate and propose revisions to the Service Area expansion process, while not pursuing Service Area expansion at this time. PLAN-Boulder County submits that such an evaluation should help to resolve the current ambiguities and inadequacies of aspects of the Service Area Expansion Plan and prepare the City and the County to consider some day far-sighted, community-based proposals that would serve the vital needs of future generations of Boulder citizens.

Boulder is regarded all over the world as a leader in environmental policies, thoughtful planning, and compact development. PLAN-Boulder County urges Council to continue to exhibit that leadership through our careful stewardship of the Planning Reserve.


The Board of PLAN-Boulder County

October 2010