HomeMy WebLinkAboutbocc.pc Woody Creek Caucus - Phillip plan update. 4-14-2026To the Pitkin County Board of County Commissioners and Planning and Zoning,
We am writing regarding the Phillips Mobile Home Park application and the newly introduced
elements that significantly alter both its scope and long-term implications.
This proposal is located outside the Urban Growth Boundary (UGB)—a fact that should be
central to its evaluation. Both the Woody Creek Master Plan (2016) and the County’s broader
policy direction, including the proposed Vision 2050 framework, are clear: growth should be
directed toward existing service centers where infrastructure already exists, not extended into
rural areas that lack the capacity to support it.
Yet this application does the opposite.
Rather than aligning with established planning principles, it proposes to introduce and scale
major infrastructure—specifically a wastewater treatment facility—into a constrained rural site,
without a defined capacity limit. This is not a neutral improvement. Infrastructure of this nature
is a growth-enabling investment, and when left open-ended, it becomes a mechanism for future
density increases beyond what is currently proposed or analyzed.
While earlier discussions referenced approximately 73 units, the absence of a firm cap—paired
with an undefined wastewater capacity—creates a framework for incremental expansion over
time. This directly conflicts with the Woody Creek Master Plan, which is explicit in its guidance:
•No new high-density development in Woody Creek
•Historical agreements not to expand over existing density
•No expansion of density beyond existing conditions for non-conforming properties like
Phillips
•Growth should not occur through incremental or procedural mechanisms that collectively
intensify development
In parallel, the proposed Vision 2050 reinforces this same principle at a countywide scale,
emphasizing that rural landscapes should not absorb growth simply because land is available,
particularly where infrastructure does not exist and must be built at significant cost.
That raises a fundamental question:
Is the County investing substantial public resources to solve a problem in the wrong location?
The introduction of a new wastewater treatment plant, water systems, and associated
infrastructure in a hazard-constrained, rural area begins to look less like responsible planning and
more like throwing good money after bad—particularly when those same resources could be
directed toward areas already within the UGB, where services, transportation, and long-term
sustainability are better aligned.
Compounding this concern is the newly introduced concept of “selling” units or lots to upper
valley employers for designated employee occupancy. This represents a fundamental shift away
from a locally serving affordable housing model toward a regional workforce housing import
strategy.
This approach:
•Imports housing demand from outside the Woody Creek community
•Functions as a quasi-commercial allocation of residential use without appropriate policy
basis
•Undermines the intent of both the Master Plan and UGB by effectively exporting
development pressure into a rural zone
Instead of supporting the existing community, the project risks transforming Phillips into a
remote workforce housing enclave, disconnected from services, transit, and the daily realities of
those who would live there.
Equally troubling is the lack of a clear and enforceable plan for existing residents. The proposal
appears to rely on relocation during redevelopment, yet provides no certainty that displaced
residents will have access to comparable, affordable housing within the valley. In today’s
housing environment, that is not a minor gap—it is a critical failure.
Without binding guarantees, this plan risks:
•Permanent displacement of long-time residents
•Relocation into housing they cannot afford
•In the worst case, contributing to housing instability or homelessness
Taken together, the revised proposal presents a series of structural concerns:
•Development outside the UGB in direct conflict with adopted planning policy
•Open-ended infrastructure enabling future growth beyond reviewed limits
•Inconsistency with the Woody Creek Master Plan’s prohibition on density expansion
•Misalignment with Vision 2050’s direction to concentrate growth within serviced areas
•Use of public funds to extend infrastructure into a constrained rural site
•Shift toward employer-driven housing allocation disconnected from local need
•Unresolved and potentially harmful displacement of existing residents
If this application is to move forward, it must be fundamentally restructured to align with the
County’s own policies and long-standing planning principles. At a minimum, this requires:
•A hard cap on total units, tied directly to a clearly defined and limited infrastructure
capacity
•Explicit confirmation that no future expansion beyond that cap will be permitted
•Elimination or strict limitation of any employer-allocation housing model
•A binding, enforceable relocation and right-to-return plan that guarantees affordability for
current residents
•A clear demonstration of consistency with both the Woody Creek Master Plan and Vision
2050, not simply in narrative, but in measurable outcomes
Absent these safeguards, the proposal sets a troubling precedent: that rural areas outside the
UGB can be incrementally developed through infrastructure investment, policy flexibility, and
undefined future capacity.
That is precisely the pattern both the Master Plan and Vision 2050 were designed to prevent.
This is not simply a housing project—it is a test of whether the County will uphold its own
growth boundaries, planning policies, and commitments to rural character.
Sincerely,
DPC
Woody Creek Caucus