April 29, 2009 Update

Friends' Response to the

Draft Area Plan

The Friends of Mt. Sanitas board has sent the following comments on the Draft Area Plan document to the City's Planning staff: 

April 28, 2009
Susan Richstone
Manager, Long Range Planning
City of Boulder
1739 Broadway Boulder, CO 80302

Re: Draft Junior Academy Area Plan

Dear Susan:

Thank you for your, and the planning staff's, considerable efforts to engage the community in the area planning process for the former Boulder Junior Academy. The workshops have been informative and helpful, and we appreciate that you and your staff have consistently been responsive and accessible.

We were anticipating that the Draft Area Plan would reflect many of the comments that we and other neighbors have offered at the workshops. And, given the substantial public process that has taken place, we were expecting a comparable level of substance in the Area Plan itself. In fact, the Area Plan does not address the concerns of the vast majority of the public who participated in the outreach process, offers little guidance to a potential developer, and contains too little information for the Planning Board to make an informed decision.

We respectfully request that the following information be included in the Area Plan before it is presented to the Planning Board:

1. Neighborhood analysis. A thorough neighborhood analysis was performed by planning staff in preparation for the April 21, 2005 Planning Board meeting. The staff went to considerable lengths to determine the existing neighborhood's density, housing sizes, housing type distributions, lot sizes, open space amounts, etc., all in an effort to define the character of the established, adjacent neighborhood.

We have repeatedly requested that this information be integrated into the area planning process. If this Area Plan does not include the previous analysis, we request that a new analysis, similar in detail, be included. Without this information, how will the Planning Board be able to determine whether the options presented in the Area Plan "support and strengthen the surrounding neighborhood," or if they are of "compatible character" as stated in the plan objectives?

2. Zoning specificity. The community is having difficulty responding to the proposal for a "flex district" when the proposal lacks specifics about which zoning parameters are flexible and to what extent they would be stretched. A flex district sounds like a developer's dream and a neighborhood's nightmare. It is hard to imagine that there could be any expectation that we would embrace such a vague proposal. We view this as a deficiency of the Area Plan but also as an opportunity to reiterate our position. We have consistently been opposed to up-zoning the site to accommodate proposals that wouldn't otherwise be permitted by the existing zoning. Given the uncertainty inherent in flex zoning, we continue to reiterate our support for maintaining the existing zoning (P on the west edge, RL-I on the remainder) or alternatively, zoning the entire property RL-I, as specified in Option I, subject to the outcome of the Compatible Development Project. (Please note that the Planning Board unanimously voted against rezoning the site at their April 21, 2005 meeting.)

3. Density and Mass. The Area Plan needs to provide more detail on the number of units and total square footage allowed under the proposed options. The previous Planning Board recommended a total build-out of 60-65K sq. ft. This seems like a perfectly reasonable guideline to include in an Area Plan and one we have repeatedly requested. This is critical to the neighborhood and key to our acceptance of the area planning process. How can the process claim legitimacy if the community's single most desired development parameter is left out of the plan?

4. Environmental analysis. When an area planning process was proposed to Council, the staff memo stated that, “As part of the area planning effort environmental concerns such as transportation, hillside development, energy use, and greenhouse gas emissions may be addressed.” We don't think these issues should be ignored and request that an analysis of these environmental concerns for the proposed options be included. Additionally, the Area Plan should provide some information about impacts to the nearby Open Space, particularly trail access and views into the site from the trail, and it should offer guidelines to protect those assets.

5. Hillside delineation. We appreciate the Area Plan's suggestion that the hillside in the northwest portion of the site be preserved and restored and would like to see more specific delineation, in the form of a map and total acreage, of the area to be protected.

6. Affordable housing. The neighborhood supports on-site affordable housing and needs more information about how that would be achieved, especially in a congregate care setting.

7. Compatible development application. The Area Plan needs to be unambiguous about how the Compatible Development Project would apply to both options. It is unclear to us how one would overlay the compatible development parameters on a congregate care site or on a site with attached housing. Additionally, without final resolution of the Compatible Development Project we're at a loss as to how to evaluate the Area Plan. If possible, it would be ideal for the community if the Planning Board's consideration of the Area Plan were to be delayed until the Compatible Development Project is complete.

8. Mapleton Hill design guidelines. The "Redevelopment Principles" portion of the Area Plan should be replaced with a simple statement to the effect that the Mapleton Hill Design Guidelines will govern site and building design. We also reject the recommendation that any large buildings on the site be consistent in size and height with the medical buildings to the south.

9. Traffic analysis. The third workshop included a traffic analysis presentation that was generally perceived to be inadequate and outdated, given that it was not based on information specific to this site or any site with similar access constraints and traffic patterns. Bicycle commuters, runners, dog walkers and parents with small children frequently use 4th St. because it is a relatively safe, clean and quiet route from north Boulder (Linden) all the way to downtown (Pearl St.). Since this issue has been critical to previous proposals as well, we request a site-specific traffic/access analysis at the Area Plan stage rather than later in the process. This analysis should include a study of the impact on traffic and circulation in the adjacent neighborhoods at large rather than simply the immediate access points and streets.

10. Issues and Concerns. The issues and concerns identified by neighbors at the first workshop and transcribed by staff remain relevant. Please include these in the Area Plan. They can be found on the City's website at http://www.bouldercolorado.gov/files/PDS/planning%20and%20zoning/issues__concerns__revised.pdf

We appreciate the many opportunities you have given the public to comment on the Area Plan, and trust that you can see many of the anonymous responses submitted via the Internet for what they are. Some of the comments included are so clearly from cheerleaders for the developer that they're laughable. To count them in the staff's quantitative summary lends them credibility as neighborhood voices and only serves to distort the truth: that the neighborhood is fairly unified in its concerns, and has expressed those concerns over and over, in person, in the workshops.

We hope you find these comments to be helpful and not too burdensome and that you will address them in the revised Area Plan that you recommend to the Planning Board. We appreciate the staff effort that this will require.

We look forward to your response and welcome the opportunity to discuss our concerns in greater detail.

Best regards,
Friends of Mt. Sanitas