Perspectives on Louisville’s New Comprehensive Plan
At its meeting on Tuesday 24 March, City Council unanimously adopted Louisville’s new Comprehensive Plan. That evening I summarized some of my perspectives on this Comprehensive Plan; here I wish to share my perspectives in more detail. As a City Councilor I owe my constituents an explanation of my perspectives, especially concerning a document of such import for Louisville’s future. Furthermore, City Council received a diversity of feedback on the new Comprehensive Plan, ranging from enthusiastic support to honest bewilderment to serious concern; here I wish to illuminate how I have processed this feedback. I organize my perspectives into three interconnected themes: principal reasons for supporting the Comprehensive Plan, remaining concerns about the Comprehensive Plan, and perceived shortcomings of the Comprehensive Plan. My reasons for support outweigh these concerns and shortcomings, but these concerns and shortcomings demand my continued attention and exertion.
Before relating my perspectives, I wish to briefly recall the content, nature, and purpose of the Comprehensive Plan. The Comprehensive Plan is the principal policy document guiding the City’s development over the next decade. Ideally, the word ‘development’ should be interpreted in its broadest sense, encompassing changes of all sorts, not merely changes of the built environment; practically, the Comprehensive Plan concentrates on land use. After some preliminaries, the Comprehensive Plan begins with the community’s Vision Statement and Values. The former reads as follows:
The City of Louisville is committed to being an equitable, resilient, and sustainable community where everyone has the opportunity to thrive—now and for future generations. We strive for a vibrant future where Louisville will evolve and adapt to change in ways that respect our past and support our high quality of life.
The latter include community character, community connectivity, environmental sustainability, economic vibrancy, community places, and civic leadership. The Comprehensive Plan continues with a series of Plan Elements—land use and development, open space, community places, economic vitality, environmental sustainability, recovery and resilience, transportation, and City core services—for each of which are enumerated a number of goals and strategies for achieving those goals. Notably falling under land use and development is the Future Land Use Map, a map of Louisville showing the types of development envisioned for the next decade. While the Comprehensive Plan establishes policies, the Comprehensive Plan is not itself a regulatory document. The Comprehensive Plan’s policies become regulatory in two principal ways: their indirect reference by Louisville’s municipal code or their direct translation into updates of Louisville’s municipal code. In either case the Comprehensive Plan significantly shapes City Council and City staff’s subsequent decision making, rendering its policies of utmost importance.
Principal reasons for supporting the Comprehensive Plan
I state and discuss two reasons for supporting the Comprehensive Plan, the latter being quite wide-ranging, and I indicate how these reasons connect to the Comprehensive Plan’s Vision Statement and Values.
The Comprehensive Plan reflects the consensus of the community’s input on Louisville’s development over the next decade. Through multiple rounds of public engagement over the past two years, City staff and consultants distilled a diversity of input into a first draft of Louisville’s new Comprehensive Plan. Following subsequent feedback from the Planning Commission and City Council and a final round of public engagement, City staff and consultants arrived at the final draft of the Comprehensive Plan that City Council adopted with minimal amendments. I trust that City staff and consultants faithfully translated the community’s input into the Comprehensive Plan and that Louisville’s elected officials and their appointees considered all of the community’s input. In this sense the Comprehensive Plan reflects the consensus of the community’s input. Of course, the Comprehensive Plan does not reflect every sentiment of every community member. I hope that the Comprehensive Plan reflects more than this somewhat narrowly-defined consensus: a community-wide consensus on Louisville’s development. One may argue that I am using the consensus of community input as an excuse for my support or that my hope is overly optimistic. While I would dispute the former argument, as I discuss below, I would agree to some extent with the latter argument.
The Comprehensive Plan will advance many of the priorities that I championed in my campaigns for City Council and that its Vision Statement and Values espouse. Environmental sustainability and housing affordability as well as economic prosperity and inclusive equity have consistently ranked as my highest priorities for Louisville. Land use policy—the Comprehensive Plan’s principal focus—can significantly advance these priorities; in shaping and supporting the Comprehensive Plan, I have worked towards this aim. More specifically to Louisville’s new Comprehensive Plan, with its emphasis on residential development, I have particularly sought land use policies that will advance the creation of equitable, resilient, sustainable, and vibrant mixed-use neighborhoods: neighborhoods more attuned to the natural world, neighborhoods home to people from all walks of life, neighborhoods interconnected by sidewalks, bicycle lanes, trails, and transit, neighborhoods supporting and supported by thriving local businesses and public entities, neighborhoods with amenities, employment, and services close at hand, neighborhoods of character and community.
The existing neighborhoods adjacent to downtown Louisville, the South Boulder Road commercial corridor, and the McCaslin Boulevard commercial corridor possess this development pattern to varying degrees. The future neighborhoods in the Centennial Valley and at Redtail Ridge envisioned in the Comprehensive Plan have the potential to possess this development pattern too. These four regions of Louisville coincide more-or-less with the Comprehensive Plan’s opportunity areas. The Comprehensive Plan directs most potential development to these areas, especially the latter two, aspiring to make these existing neighborhoods more equitable, resilient, sustainable, and vibrant and build these future neighborhoods to be equitable, resilient, sustainable, and vibrant.
More people living in such neighborhoods in Louisville will reduce these residents’ environmental impacts, especially in comparison with people living in sprawling suburban neighborhoods in other municipalities. For more people to live in such neighborhoods, we must either create more housing in existing such neighborhoods or develop new such neighborhoods. Denser housing not only allows more people to live in such neighborhoods, but also further reduces those residents’ environmental impacts. Moreover, denser residential development better supports local businesses and public entities providing amenities, services, places of employment, and transit stops in and around these neighborhoods. For people from all walks of life to live in such neighborhoods, we must ensure the creation of a wide range and significant amount of affordable housing, the proliferation of which will make Louisville more diverse, equitable, and inclusive. The Comprehensive Plan includes goals and strategies addressing the expansion of affordable housing that will hopefully position the City to make significant progress.
Starting from its Vision Statement and Values, continuing with its placetype definitions and Future Land Use Map, and carrying through to its Plan Elements’ goals and strategies, the Comprehensive Plan largely establishes such a framework for Louisville’s development over the next decade.
Remaining concerns about the Comprehensive Plan
City Council received a litany of comments expressing concerns about the new Comprehensive Plan’s potential impacts on Louisville. While I do not necessarily share these concerns, I wish to address two of the community’s most commonly held concerns. I then turn to my two principal concerns.
The population growth resulting from the Comprehensive Plan will compromise Louisville’s character as a relatively small city. I cannot—and do not—deny that Louisville’s population will very likely grow under the new Comprehensive Plan. The Comprehensive Plan does not—and may not—target any particular amount of population growth; moreover, the amount by which Louisville’s population grows over the next decade will depend on a multitude of factors over many of which the City has little to no control. While some community members have fixated on the estimated numbers of housing units potentially compatible with the Comprehensive Plan’s Future Land Use Map, I did not so fixate in shaping this map; rather, I concentrated on the form and nature of development that would suit particular areas of Louisville. The Comprehensive Plan’s placetype definitions capture much of this form and nature; accordingly, calls to reduce the residential densities within certain placetypes did not resonate. I also cannot—and do not—deny that population growth will change Louisville’s character. Recall, however, that Louisville’s population grew from fewer than five hundred at its founding to about two thousand at mid last century to about twenty thousand at present; the last century’s last few decades witnessed notable growth, with the population twice more than doubling. Yet, the majority of community members, notably excluding some longtime residents, still speak to Louisville’s character as a small town. We can work as a community, just as we have for decades past, to protect what we love about Louisville and build what we need in Louisville. The Comprehensive Plan’s placetype definitions and associated goals and strategies attempt to strike this balance.
The population growth resulting from the Comprehensive Plan will strain the City’s services. Some community members have expressed concerns about the City’s ability to continue to provide services at or near current levels if Louisville’s population grows substantially following adoption of the Comprehensive Plan. Specifically, community members worry about the capacities of the City’s water supply, recreation center and facilities, public library, police force, parks, and open spaces. In part, these concerns stem from an underlying concern about the City’s fiscal sustainability in light of the Comprehensive Plan’s land use policies. Quite frankly, these concerns are understandable and well-founded: the services that the City provides contribute significantly to our high quality of life, growth of Louisville’s population will strain the City’s existing services, and the Comprehensive Plan only speaks to maintaining service levels in the broadest of terms. Furthermore, these concerns are apt: Section 17.64.070 of Louisville’s municipal code lists the criteria for amending the City’s Comprehensive Plan, criterion B stating that an amendment “will not result in adverse impacts to existing or planned services to the citizens of the City”. As I discuss below, the City should have taken a much different approach to the continued provision of services in developing the Comprehensive Plan. Despite this shortcoming, City Council recognizes the importance of the City’s services to the community, so we will work resolutely to maintain these services as new development occurs.
The Comprehensive Plan will not adequately direct the development of the equitable, resilient, sustainable, and vibrant neighborhoods that it envisions. To be fair I am likely asking too much of the Comprehensive Plan with this concern: since the Comprehensive Plan is not a regulatory document, it cannot really direct development. Nevertheless, as City Council translates the Comprehensive Plan into regulatory decisions, will this translation suffice to effect the development of the neighborhoods that the Comprehensive Plan envisions? More specifically, how will all of the desired features of such neighborhoods—like affordable housing, communal spaces, multimodal transportation infrastructure, and local businesses—become integrated into potentially piecemeal development of multiple parcels? The City’s municipal code and other planning documents help to guide such integration, but these structures do not always suffice. I harbor particular concerns about development of neighborhoods at Redtail Ridge. My support for residential placetypes at Redtail Ridge derives from a desire to complement the hospital and employment centers with equitable, resilient, sustainable, and vibrant neighborhoods. The Comprehensive Plan’s goal for the Redtail Ridge opportunity area does not, however, emphasize this aspect of development. While I harbor much less concern about the Centennial Valley, the Comprehensive Plan could have incorporated the further step of calling for the creation of a town center along McCaslin Boulevard.
The Comprehensive Plan will not adequately prioritize infill development in Louisville. One often hears the refrain that Louisville is already largely built out (perhaps with the exception of Redtail Ridge). This statement implies that any new development in Louisville must necessarily be infill development, the development or redevelopment of parcels adjacent to already developed parcels. While this statement and its implication bear elements of truth, Louisville’s situation is more nuanced. For instance, there are some developable parcels on the City’s outskirts, particularly in the Centennial Valley and at Redtail Ridge, and some developable parcels in the City’s interior adjacent to existing open space. Development of such parcels is arguably infill development, but I would draw distinctions between development of greenfields and brownfields and blackfields as well as between development of parcels on the interior not adjacent to open space, parcels on the interior adjacent to open space, and parcels on the outskirts, generally prioritizing blackfields over brownfields over greenfields and interior parcels not adjacent to open space over interior parcels adjacent to open space over parcels on the outskirts. The Comprehensive Plan includes some promising strategies concerning infill development, but I had hoped for more nuanced direction.
Perceived shortcomings of the Comprehensive Plan
I maintain that the Comprehensive Plan has several notable shortcomings. These shortcomings principally stem from aspects of the Comprehensive Planning process, both the scope of its content and the public engagement informing this content. City Council set the Comprehensive Planning process at this process’s outset (prior to my election). Ideally, if community members disagreed with City Council’s decisions regarding the Comprehensive Planning process, then these community members, myself included, should have sought changes at this early stage. Admittedly, though, most community members do not know about City projects—let alone their detailed scope—prior to their commencement, and community members may have reasonably expected the City to include certain elements in the scope of a project like the Comprehensive Plan. Moreover, like myself, some community members may have never previously participated in any capacity in a Comprehensive Planning process, a position from which critique of scope proves challenging. Indeed, I am not certain that I could have enunciated these shortcomings two years ago. Still, with sufficient support from my fellow City Councilors, I could have directed subsequent changes. Section 17.64.070 of Louisville’s municipal code states explicitly that “City Council may consider other factors in reviewing an application as they deem appropriate and may request additional information which is necessary for an adequate review and evaluation of the amendment”. When certain community members and I expressed concerns, I never sensed that a majority of my fellow City Councilors had interest in directing changes. I enunciate these shortcomings now with an eye towards future planning processes.
The Comprehensive Plan’s public engagement process was insufficiently rigorous. City staff and consultants coordinated, conducted, and analyzed extensive public engagement over the past two years, but this engagement could have been better designed in two key respects. First, the City did not employ any statistically significant surveying to inform the Comprehensive Plan. (The City conducted a statistically significant community survey in 2024, the results of which have been used to inform the Comprehensive Plan, but this survey did not focus on Louisville’s development over the next decade.) One can conduct all the public engagement that one likes, but one can only truly have confidence in its results if one employs statistically significant techniques or samples a sufficiently large portion of the public. Given that the Comprehensive Plan is the City’s principal guiding policy document, the absence of statistically significant surveying strikes me as a considerable omission. In developing the Comprehensive Plan, I would have valued demonstrably representative public input, and the community would have valued knowing that City Council received such input. Second, the City did not employ a sufficiently iterative public engagement process. The City should have first used statistically significant surveying to establish high-level themes for Louisville’s development over the next decade and then used further rounds of statistically significant surveying to establish lower-level details. For instance, to inform the Comprehensive Plan’s vision for the Centennial Valley, the City could have iteratively inquired about this area’s desired future form, parcels for types of development, features of such development, and locations for supporting uses. Much of the public engagement occurred prior to my election to City Council. In an attempt to partially address these shortcomings, I suggested that the City conduct a brief but targeted statistically significant survey to gauge the community’s impressions of the final draft of the Comprehensive Plan. Such a survey could assess how accurately prior public engagement had captured community sentiments. Being beyond the established scope of work, conducting such a survey would have required direction from City Council to expand this scope and extend its timeline; I did not sense that a majority of my fellow City Councilors had interest in providing this direction.
The Comprehensive Plan inadequately centers Louisville’s climate goals. With the impacts of climate change ever mounting, all policy decisions should center mitigation of and adaptation to climate change. The City set itself the goal of reducing community-wide greenhouse gas emissions by 60% (below 2016 levels) by 2030, a target date falling squarely within the Comprehensive Plan’s horizon. As I discussed above, the Comprehensive Plan is far from silent on climate goals, but the City should have pursued a ‘green’ Comprehensive Plan, structuring all aspects of the Comprehensive Plan around achieving the City’s climate goals.
The Comprehensive Plan inadequately centers Louisville’s affordable housing goals. With housing becoming increasing unaffordable, especially for low-income households, all housing policy decisions should center housing affordability. The City committed to the Boulder County-wide goal of dedicating 12% of all housing units as deed-restricted affordable by 2035, a target date falling within the Comprehensive Plan’s horizon. As I discussed above, the Comprehensive Plan is far from silent on housing affordability, but the City should have structured the relevant portions of the Comprehensive Plan around achieving the County-wide goal.
The Comprehensive Plan lacks study of and planning for the City’s continued provision of services at levels expected by the community. The Comprehensive Plan includes an informative study of Louisville’s existing conditions ranging from demographics to economics to transportation. Aside from plans for future land use and strategies calling for other planning efforts, the Comprehensive Plan includes virtually no studies of or plans for the City’s provision of services in light of these land use plans and strategies. For instance, what level of growth can the City’s existing water rights accommodate, what level of growth can the City’s library and recreation center accommodate, what level of growth can the City’s open space and parks accommodate, and how much can the City expect to expand its police force? Given that the Comprehensive Plan is the City’s principal guiding document for the next decade, this absence strikes me as a serious omission. As comments to City Council demonstrated, this absence is also a serious concern for many community members. I argued at previous City Council meetings that the City should have at least generated ballpark estimates of the capacities of its existing services and of the capacity expansions of existing services necessary to accommodate growth scenarios. Such estimates would have not only productively informed the development of the Comprehensive Plan, but also meaningfully demonstrated the City’s concern for continued provision of services. To be clear, I am not suggesting that such estimates be deciding factors in the development of the Comprehensive Plan.
The Comprehensive Plan lacks fiscal analysis of its future land use framework. When setting the scope of the Comprehensive Plan, City Council decided not to conduct analyses of the fiscal impact on the City of potential land use scenarios. On the one hand, I understand this decision: the fiscal modeling that the City traditionally performs for certain developments (like Redtail Ridge) has significant shortcomings. On the other hand, I question this decision: these shortcomings implicate an inadequate model not the inadequacy of fiscal analysis itself. As any physicist can explain, if a model fails to account for all of the observed phenomena, then a better model is in order; economists must possess a similar mindset. Even some ballpark estimates of the fiscal impact of potential land use scenarios would have not only productively informed the development of the Comprehensive Plan, but also demonstrated the City’s concern for its fiscal health. To be clear again, I am not suggesting that fiscal analysis be the deciding factor in the development of the Comprehensive Plan.
The Comprehensive Plan inadequately connects its Vision Statement and Values to its Plan Elements, especially the Future Land Use Map. The Comprehensive Planning process began with public engagement and subsequent Planning Commission and City Council input on developing the community’s Vision Statement and Values. Judging from the community’s feedback on the Comprehensive Plan, I would affirm that the community almost universally agrees with the Vision Statement and Values while segments of the community clearly disagree with aspects of the Future Land Use Map. Given that the Vision Statement and Values are supposed to underlie the entire Comprehensive Plan, what explains this disconnect? The Comprehensive Plan does not contain an explanation of how the Vision Statement and Values informed the development of the Future Land Use Map. (The connections between the Vision Statement and Values and many of the goals and strategies is clear.) Above I attempted to offer such an explanation. Explicitly explaining this connection would have not only aided the community’s understanding of the choices determining the framework, but also reassured the community that its input guided these choices.
Despite my remaining concerns and perceived shortcomings, I am pleased with and hopeful about Louisville’s new Comprehensive Plan. I look forward to implementing the Comprehensive Plan’s vision for Louisville’s next decade, working to address the above concerns and shortcomings as we progress.
