November 13, 2024

To: The Boulder City Council

       The Boulder Planning Board

Re: The Urban Services Study (USS)

PLAN-Boulder County is in agreement with every point made by Councilmember Mark Wallach in his critique focused on the financial infeasibility of the Area III - Planning Reserve Urban Services Study that he posted to the Hotline on November 11, 2024.

While Councilmember Wallach focuses on the financial aspects of the study, PLAN-Boulder would like to raise several other issues. It is our view that no further work should be performed regarding Area III – Planning Reserve development until the 2025 Boulder Valley Comprehensive Plan Update process evaluates it in concert with all other potential developments. Too many additional developments are on the table now, making a particular focus on the Area III – Planning Reserve premature and misleading.

PLAN-Boulder has been analyzing housing data and environmental limitations in preparation for the 2025 Boulder Valley Comprehensive Plan Update. The only community benefit identified publicly that relates to a future annexation of the Area III - Planning Reserve has been the potential to increase affordable housing. However, our current affordable housing regulations only require one in four new units be affordable while what we need to meet our goals is one in two, so we are essentially digging our affordability shortfall hole deeper and deeper. Without an alternative approach, Boulder citizens have no reason to believe the development of the Area III - Planning Reserve will help us reach or maintain an appropriate number of affordable housing units.

PLAN-Boulder’s collected housing data shows that we have more than enough potential housing units in our already-annexed city for any reasonable future population. We have been identifying the additional housing units that have either been approved, are in the development review pipeline, or are in annexed areas that are in some state of planning for future housing development. This includes the East Boulder Subcommunity Plan with an estimate of 5,000 additional housing units; the Transit Area Village Plan with an estimate of 1,400 to 2,400 housing units; the CU South annexation agreement with an estimate of 1,100 housing units; Williams Village with an estimate of 600 more units of housing; Alpine Balsam with an estimate of up to 640 housing units with variable numbers proposed for the actual hospital site. These developments result in a total of between 8,740 and 9,740 additional housing units. While this list is by no means exhaustive, it is the best we could identify from publicly available sources

There are additional housing units that will result from increased density in residential zones as part of “Family Friendly Vibrant Neighborhoods. Zoning changes to RR-1, RR-2, RL-1 and RM-1, which purportedly can be done without changes to the comprehensive plan, can produce an estimated 5,269 units using the staff’s recommendations. Council has also indicated that they will seek more density from changes to the 2025 BVCP update, resulting in an unknown number of new housing units.

The number of estimated housing units possible in the Area III - Planning Reserve has been reported to be 6,700, and if the municipal airport is decommissioned, 2,000 more units could be built there. If the council were to decide to advance all of these projects, the total estimated new housing units would be 22,709 to 23,709. World Population Review states that Boulder’s 2024 population is 105,156, although the State Demographer shows that our population is decreasing. The current average household size is 2.18 people per unit, so an increase in housing of this magnitude indicates an assumed population growth of 49,506 to 51,686, bringing Boulder to a population of 154,662 to 156,842.

Analyzing the ability to provide infrastructure and water to the Area III - Planning Reserve alone is short-sighted and misleading when the overall potential increase in housing units (for which water taps will be required) and population (for which all city services will be required) is so much greater and must be considered carefully when establishing priorities for investment.

The City’s 2019 Updated Boulder Climate Change Water Supply Assessment has examined water supply and demand under seven scenarios of climate change, with a range of changes in precipitation and temperature taken from current national and international climate forecasts.  Under the least favorable forecast (10% reduction in precipitation and a roughly 5-degree increase in temperature), outdoor water demand increases by 40%, and Boulder’s demand restriction program is triggered every year, compared to no years under the current baseline, with more than 40% of years requiring substantial demand restrictions. This is without the many developments being proposed! It is inappropriate for Council and staff to proceed with plans for the Area III - Planning Reserve OR the 2025 update of the BVCP until a forward-looking updated analysis of Boulder’s ability to serve its projected water demands is done, taking into account these climate change factors and considering Boulder’s adopted water supply reliability criteria.

None of this includes the effects of the job growth that additional development throughout Boulder would introduce and the resulting in-commuting by employees who could not afford housing in Boulder. The number of commuters would be high since the increase in the percentage of affordable housing units would be limited. This job growth would significantly impact our transportation infrastructure unless convenient and reasonably priced alternatives to single occupant vehicles are developed.

Unless our objective is to increase our population to 150,000 or more people, we have more than enough housing units approved, in the pipeline, or part of approved planning processes without totally eliminating established, single-family neighborhoods or considering annexing the Area III - Planning Reserve at this time. We have a finite amount of developable land, and we must ensure that it is used in a manner that best benefits our citizens. The recent election is certain to introduce significant economic and political volatility across the country. Unless it is absolutely necessary, we should not rush into opening more of our precious land to development that we may not be able to control. If the Council decides to proceed with this potential to develop the Area III - Planning Reserve, it should require the work be done to carefully analyze all the financial and social impacts, then let the citizens vote on whether or not we want this for our future.

Respectfully Submitted,

Allyn Feinberg

Chair, PLAN-Boulder County