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CustCorr-2024-07-23-Q1_v1Alison BlaineCity of Boulder Planning & Development Services1101 Arapahoe AveBoulder, CO 80302303-441-4410 RE: LUR2024-00024 - 2130 Arapahoe (Naropa University) Response 07/19/2024 Dear Alison, Please see our response to the initial LUR comments dated 5/3/2024. The original staff comments are copied below inhalf-tone with all responses in bold/italics. Let us know if you have any further questions or comments. The revisedwritten statement, site plan, TDM plan and any other supporting documentation will be provided as separateindividual files with appropriate naming conventions. Regards, Bob WilsonSenior ArchitectCaddis Collaborative CITY OF BOULDER LAND USE REVIEW RESULTS AND COMMENTS DATE OFCOMMENTS:CASE MANAGER:PROJECT NAME:LOCATION:REVIEW TYPE:REVIEW NUMBER:APPLICANT: DESCRIPTION: May 3, 2024Alison Blaine2130 ARAPAHOE2130 ARAPAHOE AVE Site ReviewLUR2024-0024BOB WILSONCHARLES LIEF Proposed site review amendment for Naropa University (SI-99-4 and UR-99-7) toremove 2111 Arapahoe from the existing PUD and overall campus plan. The removalof the 2111 Arapahoe property will remove 22 parking stalls from the overall siteplan, resulting in a parking reduction over 25%. No new development is proposed forthe remaining existing main campus located at 2130 Arapahoe Ave. A TrafficDemand Management Plan (TDM) has been provided to further support any requiredadjustments to the parking requirements. I.REVIEW FINDINGS Minor plan set corrections are required before staff can approve the application and start the call-up period. Refer to thereview comments below. Please feel free to contact staff with any questions or concerns. II.CITY REQUIREMENTS The section below addresses issues that must be resolved prior to project approval. Access/Circulation Kyle Gillitzer, 303-441-43361. Within the TDM plan please expand further on how the current parking at the site is utilized. Is the parking engaging inthe principals of SUMP (Separated, Unbundled, Managed, Paid)? If so please provide some details on parking ratesper space/pass and utilization rates.Corrective Action:Transportation Demand Management (TDM) Plan Comment - Expand On Existing Parking UseFoxTuttle/Naropa: Please see the revised TDM plan. 2. Given the site has a wait list for your bicycle rental program, has Naropa considered coordinating with B-Cycle to beable to provide a discounted membership program to students as CU does. Please evaluate if this is a viable option aadvise so in the TDM plan.Corrective Action:Transportation Demand Management (TDM) Plan Comment - B-Cycle ExpansionFoxTuttle/Naropa: Please see the revised TDM plan. Legal Documents Julia Chase, 303-441-3052The Applicant must provide a Vested Rights form. This is a requirement of a Site Review application, but none wasprovided.Caddis/Naropa: A Vested Rights form is included with this response. Parking Kyle Gillitzer,303-441-4336Please see Case Manager Alison Blaine’s comments regarding corrections being required to the parking totals andpercentage of parking reduction requested.Corrective Action: Correct Parking CountsCaddis: Please refer to the attached revised site plan for corrected parking totals. Plan Documents Alison Blaine, 303-441-44101. Provide a response to the Site Review criteria listed in Section 9-2-14(h), B.R.C. 1981. Note that due to the proposedscope, some of the site review criteria may not be applicable. Provide responses to the applicable site review criteria.Caddis: Any applicable additional responses are included below. Per Section 9-2-14, BRC 1981:(h) Criteria (Site Review)(1) Boulder Valley Comprehensive Plan criteria: The site falls within the Public Zone District consistentwith the BVCP. Because no new development is proposed, the approved existing land use will not beimpacted.(2) Site Design Criteria: The TDM plan has been updated per subset (A)(iii). Open space calculationshave been updated as a result of the sale of 2111 Arapahoe, but the campus as a whole remainsunchanged and complies with the Land Use Code. Landscaping and screening has not changed as aresult of no new development.(3) Building Siting and Design Criteria: Not applicable. No new construction/development is proposed.(4) Additional Criteria for Buildings Requiring Height Modification or Exceeding the Maximum Floor AreaRatio: Not applicable. No new construction/development is proposed.(5) Additional Criteria for Poles or Emergency Operations Antenna Above Permitted Height: Notapplicable. No new construction/development is proposed.(6) Land Use Intensity and Height Modifications: Not applicable. No new construction/development is proposed.(7) Parking Reductions: Please refer to the included Site Plan and written statement for anticipatedparking reductions. 2. Include in the written statement, a response to the parking reduction criteria found in Section 9-9-6(f), B.R.C. 1981. Caddis: A parking reduction no greater than 50% is being requested with the understanding that Site Review willbe part of the approval process. A parking plan in addition to the TDM plan as indicated in 9-9-6(f)(1). The writtenstatement has been updated with the applicable parking criteria. 3.Revise the written statement with correct parking calculations. See other comments below. Caddis: The written statement has been revised with the corrected parking totals. Zoning Alison Blaine, 303-441-44101. The submitted parking table does not comply with parking calculations per the code. Parking requirements aredetermined using the total existing floor area on site. Area that meets the definition of “floor area" (see definition inSection 9-16) counts towards the parking requirements, including bathrooms, stairways, etc. Floor area that meets thedefinition of “uninhabitable space” may be precluded from floor area calculations and therefore does not contribute toparking counts. The parking calculations cannot discount the areas called “auxiliary/support” unless additionalinformation is provided to verify those areas are considered “uninhabitable space," per the code. Based on the grosssquare footage listed on the parking table (59,126 square feet), a total of 197 spaces are required where 117 areprovided. Therefore, the parking reduction request is 40%. Please update all documentation accordingly to complywith current code regulations. Remove option A and B from the table and written statement. See mark-ups to plans.Caddis: The parking totals have been revised and the options have been removed from the revised site plan.Refer to the responses below for adjustment to the revised parking totals. 2. The parking reduction is not calculated correctly. The 46% reduction is based on the original approval in 1999.However the site received approvals for several minor modifications since the original approval, which has alsoimpacted parking. The proposed parking reduction should reflect current conditions. Staff calculates the parkingreduction as 40%. Update the plans accordingly. Caddis: The total parking provided has been revised to reflect the removal of the 10 spaces at the eastern dirtlot. The net result is 107 spaces, which equates to a 46% reduction of the required 197 spaces (107/197 =54%). If staff determines that those 10 spaces are required, striping may be provided by parking lot markers (eg.TRUEGRID). 3. The site plans indicate that the site is providing 10 spaces in a small lot to the southeast. Staff cannot confirm thesmall lot provides 10 spaces because the area is unstriped. Provide more information demonstrating that the parkingprovides some form of parking dimensioning, such as curb stops, so that staff can verify parking counts. Additionally,confirm that the lot to the southwest (30 spaces) is striped. Caddis: Per the previous response, the 10 spaces at the southeast lot have been removed from the overallparking count. The 30 spaces at the southwest lot are striped by an alternate colored paver (red) as well aswhite markings at the continuous curb stops at the heads of the stalls. Please see the images below. 4. The current site does not appear to meet bike parking requirements. Per Table 9-8, 5 spaces are required perclassroom. Update the plansaccordingly. Caddis: The total classroom count for the campus is 12. As indicated in the referenced Table 9-8, 5 bikeparking spaces per classroom (at a 50/50 long-term/short-term ratio) equates to 60 required spaces. Asindicated in the TDM plan, the minimum bike parking requirement of 60 spaces is currently being met.The actual total number of bike parking spaces provided (not including the B-Cycle stations or BikeShack spaces) that remains unchanged from the current approved site plan is 95(see Site Plan). All ofthe bike parking is currently ‘short-term’ and uncovered but because the overall total of spaces providefar exceeds the required total we propose that the long-term requirement be waived. III.INFORMATIONAL COMMENTS 1. Area Characteristics and Zoning History, Alison Blaine, 303-441-4410The property is in the Public (P) zoning district. Per Section 9-5-2(c)(3), the P zone district is defined as “Publicareas in which public and semi-public facilities and uses are located, including without limitation, governmental andeducational uses." The existing use is for Naropa University, which was approved in 1999 (UR-99-7 and SI-99-4).Subsequent minor modifications have been granted since 1999 for the addition and removal of accessory buildingsand related parking reductions/deferrals (ADR2004-00055, ADR2004-00056, ADR2008-00167, ADR2012-00267).surrounding zones include P to the east and south, and RMX-1, RH-2, and Rh-1 to the west and north.Caddis: Acknowledged. 2.Legal Documents, Julia Chase, 303-441-3052 The Applicant will be required to sign a Development Agreement, if approved. When staff requests, the Applicantshall provide the following:a. an updated title commitment current within 30 days; andb. documentation confirming authority to bind.Caddis/Naropa: Acknowledged. 3. Next Steps, Alison Blaine, 303-441-4410 Revisions to the plan documents are required. Resubmittal materials thataddress the comments herein shall be uploaded through the “Attachments" tab in the CSS portal(https://energovcss.bouIdercoIorado.gov/EnerGov Prod/SeIfService/#/home) using the naming conventions in theElectronic Submittal Requirements for Development Review/ Plan case document available here:https://bouIdercoIorado.gov/media/1447/downIoad?attachment.Resubmittals should have thefollowing componentDevelopment Review Resubmittal form (https://bouIdercoIorado.gov/sites/default/files/2021-06/PLNResub.pdf . • Awritten response identifying all changes made, saved as a PDF file. (See requirements). • FULL set of electronicdrawings and/or affected documentation addressing the review comments. (Named as specified intherequirement. • Revised plans must include the date of ALL revisions. These must be saved as PDFs. (See requirements). Theapplication deadlines for the review track system can be found at https://bouIdercoIorado.gov/plan-develop.Feesshall be paid, and files uploaded to the customer self-service portal for resubmittals by 10 AM on the applicationdeadline Staff is happy to meet with you to discuss these comments in detail at your convenience. Caddis: Acknowledged. 1. Review Process, Alison Blaine, 303-441-4410The development proposal involves amending the previous Site Review approval to remove the lot at 2111Arapahoe from the boundaries of the existing previous review. Additionally, a parking reduction request of greaterthan 25% must be reviewed through a Site Review process. Therefore, a Site Review Amendment is required.Pursuant to section 9-2-14(m), which states that “no proposal to modify, enlarge or expand any approved sitereview will be approved unless the site plan is amended and approved in accordance with the proceduresprescribed by this section for approval of site review.” A Site Review Amendment is subject to a staff level decisionand a 14-day Planning Ba call-up period. During the call-up period any member of the board of public may call theitem up for public hearing. which case, a public hearing will be scheduled within 60 days.Caddis: Acknowledged. II. FEES Please note that the new 2024 application fee includes an initial and two subsequent reviews. If further substantive review is required following the third review, an additional fee will need to be paid for the fourth and each subsequentreview. This additional fee does not apply for: Annexation/Initial Zoning, Concept Plan Review, BVCP land usedesignation change, Vacation Feasibility Study, Right-of-Way/Access Easement Vacation, or CDOT Access Permit. Caddis: Acknowledged. For 2023 or earlier cases, hourly billing still applies for reviewer time spent on any reviews following the initial review.