GMWSD Objection to Lakewood Comprehensive Plan 22 August 2025
This letter serves as formal notice that the Green Mountain Water & Sanitation District (GMWSD) objects to Lakewood’s Comprehensive Plan, titled Envision Lakewood 2040, which was passed unanimously by City Council on 28 July, 2025.
Pursuant to C.R.S. 24-32-3209(2)(b) this written objection is being sent within thirty days after the adoption of the plan by a neighboring jurisdiction. Per C.R.S. 31-23-206(1.3)(b), Green Mountain qualifies as a neighboring jurisdiction that supplies water to the area covered by the master plan.
Therefore, GMWSD objects to and requests mediation to resolve the following issues:
- Densification plans that will require extensive flow modeling and rate analysis to accommodate the new zoning for which the existing infrastructure was not originally designed
- Densification plans that require commercial connections on current residential property
- Densification allowances throughout entire areas where there is not existing adequate infrastructure
- Removing occupancy limits without use restrictions
- Reduced property setbacks that may hinder infrastructure access and maintenance.
- Leading residents to believe that additional units may be built without consideration of pipe capacity or associated fees.
- Inadequate study and projection of future housing projects resulting from new plan and subsequent zoning code changes
- Inadequate study of the water and sewer infrastructure needed throughout all zoning codes
- Inadequate study of the costs involved for new water and sewer projects that will be passed on to residents, which may make new building unaffordable.
- Proposed zoning code changes should be halted until there is a plan, funding, and construction schedule in place for increased infrastructure
These objections are a result of goals and strategies, as stated in the comprehensive plan and that are listed in the attached document, which will:
- Eliminate single-family zoning
- Mix commercial and residential infrastructure
- Increase needed pipe capacity overnight
- Make water use decisions, such as preferential treatment of human consumption over environmental watering
- Promotion of urban expansion in areas without supporting infrastructure.
84% of the plan’s goals and over 10% of its strategies involve new housing and/or commercial spaces. These changes depend on having adequate water and sewer infrastructure yet to our knowledge, none of Lakewood’s special districts have been contacted for input.
GMWSD data models are dependent on Lakewood’s zoning and development plans. All data has shown that GMWSD is almost completely built out, and that’s how we have projected growth and assessed fees for years. Changing the data model with one vote can not only cause severe mismanagement and inadequate
infrastructure but can cause unexpected fees to residents who have been made false promises of “affordability.”
Decades of water conservation efforts have led to a hardened system – there is very little room to eliminate watering one yard and repurpose that water for multiple toilets and showers instead. Promoting increased housing is a key part of Lakewood’s vision for the future and is mentioned 229 times in the comprehensive plan. Collaboration and mediation are necessary to ensure adequate water and sewer infrastructure for this vision to be achieved.
Please provide a written response to these objections and identify a timeline for mediation within 90 days of the date of this letter. GMWSD is open to a wide range of alternative dispute resolution processes and prefers to utilize a neutral professional recommended by the Central Region Regional Manager.
Thank you,
Karen Morgan, President
Green Mountain Water and Sanitary District
Karen.morgan@greenmountainwater.org
Inc: Pertinent Goals and Strategies
Cc: CityCouncilMembers@Lakewood.org, cmo@lakewood.org, board@greenmountaintwater.org, jstanley@greenmountainwater.org
Pertinent Strategies (Referencing all but FOUR goals)
| Strategy | Description | Impact |
|---|---|---|
| Strategy 2 | Equitable Access to a Healthy Life: Prioritize efforts to ensure equitable access to resources that help all residents enjoy a healthy life (e.g.,, access to food, medical care, safe housing, transportation, arts, parks, recreation, outdoor spaces, and others.) Primary Goals: 1 Secondary Goals: 3, 4, 8, 9, 11, 2 | Promotes mixed-use zones without adequate infrastructure |
| Strategy 3 | Healthy Food Access: Engage with community partners to identify gaps in healthy food access. Support and encourage efforts to fill those gaps through actions such as community gardens, farm stands, fresh food distribution in local stores, attraction of new grocery stores, retention of existing grocery stores, regulatory changes, food rescue, education for gardening, and preservation and others. Primary Goals: 1 Secondary Goals: 3, 23 | Promotes small-scale retail into residential neighborhoods – requires commercial connection |
| Strategy 10 | Safe and Resilient Infrastructure: Develop and maintain green and gray infrastructure that supports public health and safety, reduces risk of hazards, integrates into pedestrian-friendly streetscapes, and supports a healthy natural environment through implementation of nature- based solutions that promote climate mitigation, adaptation, and resilience. Assess and identify opportunities to mitigate existing hazards and enhance climate resilience of infrastructure, city assets, and communities. Primary Goals: 2, 18 Secondary Goals: 1, 4, 8, 9, 14, 15, 16, 17, 21 | Promotes water use strategies that reduce system resilience and makes emergency planning more difficult Promotes increased erosion, air pollution, and noise while reducing neighborhood interactions by limiting options for a healthy lawn |
| Strategy 40 | Water Efficient Homes, Buildings, and Landscapes: Reduce water consumption in alignment with regional water goals by ensuring that city codes support water efficient development and by providing resources, technical support, and incentive programs that encourage Lakewood residents and businesses to implement indoor and outdoor water efficiency and conservation measures. Primary Goals: 7 Supporting Goals: 16 | Promotes water use strategies that reduce system resilience and makes emergency planning more difficult Promotes increased erosion, air pollution, and noise while reducing neighborhood interactions by limiting options for a healthy lawn |
| Strategy 75 | Creative Entrepreneurship Opportunities: Foster creative entrepreneurship by ensuring City policies support incubator and start-up spaces, funding opportunities, and business development resources for artists, cultural enterprises, and individuals wishing to pursue creative ventures in Lakewood. Strategically encourage these activities in locations where there is already a concentration of creative activity or where the introduction of new creative activities could breathe life and activity into new spaces. Primary Goals: 12 Supporting Goals: 11, 23 | Promotes mixed-use zones without adequate infrastructure Promotes small-scale retail into residential neighborhoods – requires commercial connection |
| Strategy 77 | Opportunities for Diverse Industries: Continue to encourage a mix of land uses to attract diverse, innovative and sustainable industries. Primary Goals: 13 Supporting Goals: 23 | Promotes mixed-use zones without adequate infrastructure |
| Strategy 80 | Support Area Planning in the City: Implement a collaborative approach to develop context sensitive area plans for targeted corridors, neighborhoods and activity hubs, prioritizing areas with high redevelopment pressure, displacement concerns, environmental hazards, infrastructure needs or other factors to create equitable planning processes. The outcome of these plans can help identify area assets and opportunities for change that are reflective of community input and cohesion. Primary Goals: 13, 14, 15, 17 Supporting Goals: 4, 5, 12 | Promotes mixed-use zones without adequate infrastructure Promotes small-scale retail into residential neighborhoods – requires commercial connection |
| Strategy 81 | Implementation Tools for Context-Sensitive Development: Use the City’s implementation tools such as the Zoning Ordinance, Design Standards, Major Site Plan Review and other applicable regulations to promote development that is | Promotes mixed-use zones without adequate infrastructure |
| Strategy 93 | Diversity of Housing Types: Encourage a mix of housing types through development regulations, policies, and incentives to accommodate different household sizes, income levels, preferences, and needs. Primary Goals: 17, 19, 25 Supporting Goals: 3, 4 | Promotes mixed-use zones without adequate infrastructure Promotes water use strategies that reduce system resilience and makes emergency planning more difficult |
| Strategy 95 | Mixed-Income Neighborhoods: Promote mixed-income developments throughout the city to ensure integration of neighborhoods of all incomes. Primary Goals: 17 Supporting Goals: 1, 3, 19 | Promotes mixed-use zones without adequate infrastructure |
| Strategy 96 | Create Walkable, Connected Neighborhoods: Encourage land uses that integrate housing, employment, and community amenities within walking distance of each other. Primary Goals: 17 Supporting Goals: 1, 2, 19, 21, 22, 23 | Promotes mixed-use zones without adequate infrastructure Promotes small-scale retail into residential neighborhoods – requires commercial connection Promotes water use strategies that reduce system resilience and makes emergency planning more difficult |
| Strategy 99 | Encourage Climate-Conscious Neighborhoods: Promote sustainable practices throughout neighborhoods, with a focus on energy efficiency, water conservation, green infrastructure and zero waste. Primary Goals: 17 Supporting Goals: 1, 19 | Promotes mixed-use zones without adequate infrastructure Promotes water use strategies that reduce system resilience and makes emergency planning more difficult |
| Strategy 106 | Minimize Displacement: Minimize the involuntary displacement of vulnerable populations, such as low-income households, older adults, and people with disabilities, as the city grows and changes. Use tools to allow reinvestment in and preservation of existing housing stock, and allow appropriately scaled infill such as accessory dwelling units, duplexes, and tandem houses. Primary Goals: 19 Supporting Goals: 3, 20 | Encourages high-cost ADU development Promotes mixed-use zones without adequate infrastructure |
| Strategy 138 | Transit Oriented Communities and Community Oriented Transit: Support greater density in areas well-served by transit and greater transit service and a greater variety of transportation options in denser areas, while ensuring a dense pedestrian-network where residents have safe and convenient access to destinations and the transportation network, while also considering area context. Primary Goals: 7, 21 Supporting Goals: 13, 15 | Promotes mixed-use zones without adequate infrastructure Promotes small-scale retail into residential neighborhoods – requires commercial connection Promotes water use strategies that reduce system resilience and makes emergency planning more difficult |
| Strategy 143 | Walkable Community: Improve the pedestrian environment to ensure that residents and community members have safe, comfortable and convenient access to destinations such as schools and the public transit network. Consider the development of a walkability plan that would also include information and education programs to improve transportation safety and wayfinding. Primary Goals: 22 Supporting Goals: 1, 14, 17, 21 | Promotes mixed-use zones without adequate infrastructure Promotes small-scale retail into residential neighborhoods – requires commercial connection Promotes water use strategies that reduce system resilience and makes emergency planning more difficult |