Fundamentally, we do not believe that the proposed moratorium is good policy. The current system, in which the merits of individual proposals can be judged using the site plan review criteria, allows the city to understand the benefits and impacts in a much more informed way than a somewhat arbitrarily drawn limitation. We are also concerned that such a far reaching change was proposed with no public process or analytical work to support it.

However, if the council does choose to move forward with this proposal, there are a number of changes we would suggest to make it less damaging. First, the boundaries should be adjusted to include the Boulder Valley Regional Center. The BVRC is identified in city plans as the area expected to be developed at the highest intensity in the community – and the proposed height restrictions are totally inconsistent with prior planning for this area,.

Much of the area is dominated by large surface parking lots, pedestrian unfriendly arterials, and strip style development. During the efforts to redevelop the Crossroads mall, the city attempted to negotiate with Macerich to get a far more urban redevelopment, including significant housing. The negotiations were unsuccessful, but we have seen some incremental change, such as the development of 29 North in the old Macy’s “Thanksgiving parking lot”. With the Boulder Junction area redeveloping, it seems very inconsistent to limit similar opportunities in the BVRC. We are also concerned that there should be an ability to consider adding other areas, so that the planning for redevelopment is not arbitrarily limited.

We also would recommend that there be an affirmative council vote to renew every six months, so that council can evaluate whether there are unintended negative consequences.