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1.   Take a step back and get input from all citizens.

The co-op ordinance is being rammed through the legislative process with input from only the co-op activists.  There has been no attempt to gather input from homeowners in any of the neighborhoods that will be impacted.  This is an important issue with long-term effects, and needs to be though out clearly, carefully, and slowly.  There is no reason for the false sense of urgency behind this ordinance.

 

2.   Neighbors must have a say when being subjected to up-zoning.

The co-op ordinance is a de facto up-zoning of existing Low Density Residential neighborhoods. The intention of existing zoning designations is to provide some security and certainty about the long-term character of a neighborhood to homeowners who are investing a significant portion of their financial futures in their homes; the proposed co-op ordinance subverts that purpose with no recourse for homeowners.  The ordinance needs to provide for neighborhood input on co-ops, either through conditional-use review, or direct participation in the licensing process.

 

3.    Keep co-ops in compatible high-density zones.

Co-ops are just not compatible with low-density residential neighborhoods.  It is not just a matter of noise, trash, weeds, and cars.  Aesthetics, continuity, and population density all contribute to the character of a neighborhood.  High-occupancy co-ops belong in higher-density neighborhoods, not low density single family areas.

 

4.     Co-op rules will be unenforceable.

Many of the people advocating for co-ops have already demonstrated that they feel justified in ignoring laws and rules that they don’t like, such as existing occupancy limits.  The City of Boulder has also demonstrated a lack of pro-activity in enforcing existing ordinances.  No matter how many rules and regulations are written into this ordinance, we have little faith that the co-op residents will actually observe them or that the city will make an effort to enforce them.

 

5.    Neighborhood impact must be limited.

If co-ops are to be allowed in low-density residential neighborhoods (in spite of our serious objections), then there must be some attempt to limit the impact on those neighborhoods.  There must be a limit of how many total co-ops are allowed in specific neighborhoods.  There must be a limit on total density within sub-neighborhood areas, e.g. no more than 1 co-op per block, or within a 1000 foot radius.

 

6.    Co-op certification process is troubling.

The “co-op certification” process is vaguely defined and amounts to little more than self-regulation by the co-op interests themselves with no meaningful oversight by government.  Citizens are being asked to trust the good intentions of people who have already demonstrated their willingness to pick and choose which laws they follow or ignore.

 

7.    Rental co-ops have a high potential for abuse and negative impacts.

The rental model of co-op license is troubling no matter how it is structured.  A rental co-op is functionally indistinguishable from a boarding house, tenants will be largely transient, and investor landlords will easily subvert and abuse this process.  Even if this co-op ordinance is destined to be approved, the rental model should stricken from it and reworked from the beginning.

 

8.   Neighborhoods should get some tangible benefit in exchange for accepting the burden of co-ops.

If co-ops are to be allowed in low-density residential neighborhoods (in spite of our serious objections), then homeowners in those neighborhoods need to get something in exchange for giving up the guarantees of low-density zoning.  The city should guarantee budget and direction for serious pro-active enforcement of occupancy limits and other nuisance housing problems.