Site Review may change—but is it for the better?

Virtually all Missing Middle Housing projects in Boulder must go through Site Review

This article is written by one of our new contributors and editors: Kurt Nordback. Kurt moved to Boulder with his family at age 4. He grew up on University Hill, attending Boulder schools and CU. Professionally he is a software engineer, but his real passions are urban design and transportation policy.

It’s famously difficult and expensive to build in Boulder. That’s part of why housing is so pricey: a long, arduous, unpredictable process deters many developers from even attempting to do a project here. For those brave ones who do, the process drives up the cost, in the end making homes more expensive.

So let’s look into that process. There are two basic pathways to getting a housing (or indeed any) project approved in Boulder: Administrative Review and Site Review. Administrative Review applies to small, simple projects, like building a single detached house or an accessory dwelling unit or a small “plex” (in the few areas where those are allowed and practical). Under this process, city planning staff alone review and approve proposals. For larger projects – think the affordable housing proposed at the Geographic Society of America site, or the transitional housing to be built at Grace Commons, or pretty much any large housing project you’ve seen go up in the city in recent decades – the process is called Site Review. Site Review requires projects to meet a slew of additional criteria, and then get approved by Planning Board. If Administrative Review is jumping a series of hurdles, then Site Review is a mix of hurdles and high jumps and long jumps, over a much longer course.

In 2018, at the direction of a City Council that was critical of some recently-built developments and rather skeptical of development in general, city staff began a long process to update those Site Review criteria, with instructions including to “identify incentives to address the community economic, social and environmental objectives of the [Boulder Valley] comprehensive plan” and “identify other aspects of the Site Review criteria to further city goals and create more predictability in projects”. Staff are now ready to bring forward their draft of the revised criteria for approval by Planning Board on May 19, and for review by City Council soon after.

The reference to “predictability” in the project objectives is especially key. The current criteria require that a project be consistent “on balance” with the policies of the Boulder Valley Comprehensive Plan. But the BVCP contains policies that are often hard to reconcile, like “protect neighborhood character” and “encourage property owners to provide a mix of housing types”. Where the “balance” between those lies can be a question of much debate.

The city staff proposal makes the Site Review criteria much more prescriptive, taking inspiration and terminology from Boulder’s Form-Based Code. The FBC, which governs new development at Boulder Junction, consists of nearly 500 rules for building form, design details, materials, and more. Staff’s draft Site Review criteria remove the “on balance” language and instead include a subset of the FBC rules, plus detailed requirements for things like acoustic mitigation of external noise and more stringent energy conservation. Then, because the draft criteria are strict and detailed, the proposal also introduces a new, additional “alternative compliance” approval pathway for projects that require more flexibility.

If this sounds like something that’s already complicated getting more complicated, you’re right. The draft criteria exchange ambiguity for rigidity, and more general goals for highly specific requirements. They may prevent mediocre buildings; but by tightening requirements they may also prevent some buildings that many Boulderites would support from happening altogether. 

To address our housing crisis, Boulder needs buildings. It needs small buildings and big buildings, quotidian buildings and stand-out buildings. Not every building needs to be, or even should be, an architectural masterpiece. Particularly large or prominent buildings should be well-designed, but our processes should allow for more affordable, workaday design in moderate-sized buildings.

To that end, our Site Review criteria should give clear guidance without rigidity. The current criteria arguably don’t give enough guidance for what a building must do to meet them. The draft criteria, on the other hand, either are extremely rigid or, if a project chooses the “alternative compliance” pathway, provide too little guidance.

The staff proposal completely misses another important aspect of Site Review: the thresholds that require projects to go through Site Review in the first place. For a housing advocate, the current thresholds are highly problematic, because many of them are based on the number of units proposed. Imagine you’re planning a small housing development in a residential zone in Boulder, where the threshold for Site Review is five units. If you build five units, you’ll need to submit a detailed Site Review application; wait months (or perhaps more than a year) to appear before Planning Board; and hope for approval with a minimum of changes or additional requirements. If, on the other hand, you build four (somewhat larger, and therefore more expensive) units, you can avoid the time and uncertainty and additional costs of Site Review, and get staff-level approval as long as you meet the code requirements.

Given that choice, any sensible developer would choose the second option of building fewer units. But that’s the wrong outcome in terms of addressing Boulder’s housing availability and affordability crises. That’s why thresholds should be based on overall size (land area or proposed floor area, for instance) rather than number of units. And projects that are mostly or all affordable housing arguably shouldn’t be forced through the Site Review wringer at all.

City staff have done an absolutely admirable job trying to meet the goals of the Site Review update project set by a previous City Council that was at best unclear and at worst schizophrenic in what it was trying to achieve. But in the end, the draft criteria don’t meet the city’s needs and goals. The project should be sent back for another round, to simplify and clarify the Site Review process, create criteria that provide guidance without rigidity, and address the shortcomings of the unit-based thresholds.

How to listen in and speak at the Planning Board public hearing May 19, 2022 when this matter will be discussed. The link to join the Planning Board Zoom meeting is posted here 24 hours before the hearing. To read the Planning Board packet with proposed changes to the Site Review criteria, go here. If you cannot attend, you can email your thoughts to Planning Board at

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