. The Proposal Does Not Meet the Criteria for a Rezoning. • The Proposed Rezoning is Inconsistent with Blueprint Denver (DZC § 12.4.10.7.A). • Inappropriate use of large scale development in an Area of Stability – The neighborhood in which the rezoning is proposed is an Area of Stability. Yet, the proposed rezoning seeks significant change. Contrary to the City of Denver Community Planning and Development (CPD) staff report statements, the proposed development is large scale – and would be surrounded by residential property with only limited exception. Other than the 32nd and Lowell shopping center at the Neighborhood Center (which is comprised of many small businesses), if approved this commercial lot would be the largest commercial property in the neighborhood. Furthermore, there are few 2-story properties along 32nd Avenue that are full commercial use on all floors as proposed for the property in question. Virtually all of such 2-story properties along 32nd Avenue are mixed-use with small commercial entities on the street level and residential or mixed use on the second floor. • Not in Neighborhood Center – While Blueprint Denver allows limited revitalization in a Neighborhood Center of an Area of Stability, the property in question is not within the Neighborhood Center. Instead, Blueprint Denver states that the Neighborhood Center is at Lowell Street and 32nd Ave, ending two blocks west of the subject property. Thus, even if the West Highland neighborhood needed revitalization (it clearly does not), the subject property falls outside of the area in which such revitalization is permitted in an Area of Stability. • The current zoning of the property is not incompatible with the surrounding properties – Blueprint Denver also permits limited change to address incompatible zoning. But there is nothing incompatible about the zoning of the property. The property is surrounded by U-SU-A zoning in all directions. The fact that a single U-MX-2x zoned property to the west of the subject property on 32nd Ave. and a PUD to the east along Speer Blvd. does not make the current U-SU-A for the subject property incompatible. If anything, the U-MX-2x property and PUD are small islands in a sea of much less intense U-SU-A zoning. • The Proposed Rezoning Is Inconsistent with Public Health, Safety, and General Welfare (DZC § 12.4.10.7.C). • Insufficient road infrastructure – Nearby intersections simply cannot handle the dramatic increase in traffic that will occur if the rezoning is permitted. Irving Street one block to the north and 32nd Ave one half block to the east both dead end and do not allow for heavy through traffic. Additionally, both streets are narrow and do not allow for turn lanes, notably limiting traffic flow. Additionally, the 32nd a Ave and Speer Blvd. intersection, one half block from this property, does not function well, and is a high-risk intersection for pedestrians with heavy traffic flow, misaligned streets, and unclear views for pedestrian crossing. This intersection is a walking route for neighborhood students to the North High School campus and nearby Skinner Middle School, as well as to the Woodbury Public Library. The significant increase in traffic flow at this intersection that will result from this rezoning is a notable risk to students and other pedestrians. If this rezoning is approved and the planned development completed, the residential neighborhoods surrounding the property will witness a dramatic increase in traffic in an already heavily congested area, which will lead to more accidents, injuries, and fatalities. • There Is No Circumstance Justifying the Rezoning (DZC § 12.4.10.8). • There Has Been No Change to the Neighborhood Justifying the Rezoning – The CPD Report states that the “justifying circumstance” for the rezoning is that the neighborhood has changed or is changing “to such a degree that it is in the public interest to encourage a redevelopment of the area” (DZC § 12.4.10.8.A.4). Anybody who has been to the West Highland neighborhood knows, however, that it does not require redevelopment. The neighborhood has already undergone a significant redevelopment and for some time has been one of the most sought after by both individuals and families seeking residential property and commercial entities seeking commercial property. Quite simply, this rezoning is unnecessary to encourage the development of the subject property. • The Fact that Emmaus Has Chosen Not to Use the Subject Property Cannot Create the Circumstances Justifying the Rezoning – Emmaus and the developer have pointed to the Church’s decision to stop using the subject property as a school as a circumstances justifying the rezoning. This makes no sense. If City Council accepts this argument, it would then allow property owners who desire the windfall of a significant up-zoning to allow their properties to fall into disuse and disrepair. City Council should not create such an incentive by accepting the argument of Emmaus and the developer. • The Proposed Rezoning is Inconsistent with the Neighborhood Context (DZC § 12.4.10.8.B). • Rapid neighborhood growth – The West Highland neighborhood is experiencing rapid growth as evidenced by the significant number of high-rise buildings being built at Lowell Blvd. and 32nd Ave, Meade St and 32ndAve, W. Moncrieff Pl. and 33rdAve, Lowell Blvd and 38th Ave. and Julian St and 38th Ave. and conversion of Julian St and 32nd Ave senior high-rise building to non-age restricted residential units. This magnitude of change is impacting density dramatically within the area and this existing development within the neighborhood must be considered. Current unplanned growth should not justify more change; it should underscore that more direction in planning is needed. • 2-Story 100% Commercial Buildings Are Inappropriate – With one exception, there are no 2-story commercial buildings in our neighborhood that are not mixed-use. The reason is simple – such buildings have no place in the West Highland neighborhood. Instead, mixed-use properties along 32nd Avenue are what currently exists and are consistent with the neighborhood context. • The Proposed Rezoning Would Permit the Largest Building parcel in the West Highland Neighborhood to be Built – Under the applicants requested up-zoning code this lot could be developed into the largest commercial building in West Highlands. This is not small scale development meant to infill unused or underutilized parcels, this is large scale commercial development that is inappropriate for this neighborhood.