An Unacceptable Plan for a City that Prioritizes Sustainability

The General Development Plan (GDP) submitted to the City of Louisville on January 27, 2021 represents an incohesive sprawling development and includes minimal elements of sustainability planning. The city of Louisville should reject this plan and require a plan with a sustainability focus.

The plan spreads development to the edges of the property, with few elements of cohesive design. The GDP proposes to maximize the square footage allowed under the Comprehensive Plan[i] and includes building heights that exceed limitations in city code[ii]. The layout involves 12 parcels (5 parcels subdivided into sub-parcels) with flexible boundaries between each. The 5 large parcels are not grouped in a way to leave a visual buffer as viewed from the perimeter. Brue Baukol (BB) would like to reserve the right to transfer square footage between the parcels, transfer height allowances, and add parking structures that are not counted towards to total developed square footage.[iii] BB has not committed to any specific building placement and would like to have the option to add an internal road network[iv]. Most importantly, the development is spread over the entire property, with minimal open space dedication, and no consideration of a visual buffer or existing wildlife.

A sustainability plan is still needed.

The GDP was submitted along with a document titled, “Redtail Ridge Sustainability Goals and Approach”. This sparse document includes a bold "requirement" for silver-level LEED certification for some buildings, but few other commitments to go beyond status-quo [vi]. This document mentions that BB will "explore" and "encourage" innovative ideas, however, it is not a substitute for a plan with concrete actions and commitments.  A sustainability plan is still needed.  

Unfortunately, the document is missing a key principle of sustainability; an integrated system approach. Sustainability needs to be a focus at the master design level of this GDP.  For example, the goal to preserve the high value habitat areas " while enhancing and creating new areas and corridors  throughout the site" is notable.  But, the GDP shows no such areas or corridors.  The GDP should identify the new areas and corridors and design the parcel layout around them--not visa--versa. Likewise, it makes no sense to request approval of the current design if a "habitat management plan for all 400 acres" and a "green infrastructure plan" are still forthcoming. 

This document addresses energy, water, transportation, and health, but doesn’t include enough specific commitments. It also fails to address the many sustainability issues brought up by stakeholders in previous reviews and public hearings such as dark skies, reduced parking area, and preservation of wildlife habitat.  

The Louisville Sustainability Advisory Board requested Conformity to the City Sustainability Action Plan. 

The city Sustainability Action Plan sets goals for the city in terms of climate, energy, transportation, waste, water, ecological health, and local food and agriculture. The plan describes the city’s goals to lead by example in these areas. These goals, objectives and strategies are worthy of review for external entities striving for exemplary measures.

In addition, the plan includes the following objectives and strategies aimed at commercial/industrial entities within Louisville. All of these have a place in the GDP.

• Require climate benchmarks.

• Participate in energy efficiency and renewable energy programs.

• Engage in water conservation efforts.

• Adopt zero waste collection, set commercial diversion goals including from construction.

• Follow recommendations in the Transportation Master Plan

• Participate in community goal for Bronze or Silver Bicycle-Friendly Community status.

• Ensure new development is EV ready.

A sustainability plan for Redtail ridge should incorporate the partnership recommendations in the Sustainable Action Plan. It should also comply with the guiding documents listed as incorporated into the plan.

County-Level Stakeholders want to see environmental impacts reduced.

County officials and staff reviewed the previous GDP and asked that city and developer utilize much stronger measures to address environmental impacts such as traffic and pollution and loss of open space and buffers. The  county communication [ix] also included multiple criticisms of the 2020 traffic study.  A review of the new traffic study released February 2021 is not available as of Feb 5, 2020.  

A primary concern in the county communication was that the development was too large. Though the development will be scaled back in the 6th GDP, many of the recommendations remain applicable. The recommendations below are not listed in priority order. The context and tone of these recommendations is provided in the original communication and is only summarized here.  

Traffic

• Require “an aggressive implementation plan and performance requirements” to reduce non-single-occupancy vehicle (SOVs) with consequence for not meeting the non-SOV goals.

• Avoid road widening because it increases conflicts with bikes and pedestrians, increases speeds and conflicts with goals of the comprehensive plan.

• The Traffic Impact Study should focus on moving people, not cars. Changing the focus may result in different recommendations. For example, instead of widening roads, traffic can be mitigated by creating wider walking paths, bike, and transit lanes.

• Parking should be limited, paid or both. (Limiting the vehicular parking spaces also reduces the impervious surface area preventing stormwater runoff and downstream pollutants.)

• Provide Employee Eco Pass for all employees working within the proposed development. (Boulder County has a program to help subsidize the first two years of the program)

• Include other commuter incentives, e.g. vanpool vouchers, give carpool and users preferential or guaranteed parking.

• Include good transit service ( e. g., high frequency, numerous routes)

• Help achieve Vehicle Miles Traveled reduction goals found in the Boulder County Transportation Master Plan and the Louisville supported MetroVision 2040 Plan

• Review the history of circulator use in Louisville and guage community interest in restarting such a service in the next several years.

• Explore automated vehicles to connect the Park-n-Ride to destinations throughout the development.

• Add secure, covered bike parking. Make parking a bicycle both dignified and safe.

• City and developer should provide easement along eastern edge for trail connection. (NW Pkwy/ 96th Street)

Environmental Resources

• City should require the surveys and consultations recommended in the Biological Assessment.

• Relocate the construction staging area within the development site upon land planned for a future development phase

Climate Change and Energy Resources

• Minimize or eliminate the use of natural gas appliances. Electrification of buildings can be achieved by installing electric heat pumps in lieu of gas -fired boilers, furnaces, and water heaters. (Note area is non-attainment status for ozone national ambient air quality standard.)

• Ensure that the new development is a model for sustainability and reflects climate change adaptation -related planning principles.

• Take steps to minimize water use, maximize energy efficiency and use of renewable energy, and minimize the footprint of structures and impermeable surfaces.

Water and Drainage issues

• City should institute a requirement that the proposed urban drainage plan not create water quality or quantity issues that would impact the integrity of Rock Creek.

• Ensure drainage from trail along Goodhue ditch does not impinge upon existing legal rights of ditch company.

• Boulder County review is required for urban drainage

Community Buffer

• Move development from HWY 36 corridor to protect the aesthetic of the corridor.

• Adjust location and bulk of development to maintain buffers.

• Comply with IGA signed in 1999 to "... preclude increased development and urban sprawl which would obliterate the boundaries of Broomfield, Lafayette and Louisville...."