The lawyerly list of grievances with The Ridge apartments paints a picture of city officials ignoring building codes, zoning regulations and disabled access laws, potentially putting residents of the Broadmoor Bluffs neighborhood at risk.
To Lee Patke, however, the complaints represent a thinly-veiled attempt at keeping low-income families from moving into his proposed affordable housing complex.
"We believe the core issue continues to be the nature of the people who are going to live there," said Patke, executive director of the nonprofit Greccio Housing, a partner in the development.
Nearly a year after resistance surfaced to the 60-unit apartment complex, the project remains mired in dispute amid opposition from the surrounding Broadmoor Bluffs neighborhood.
On Thursday, the Broadmoor Bluffs Neighborhood Association is expected to take its fight to the Colorado Springs Planning Commission. The neighborhood group immediately appealed a development plan and final plat for the project, which city planners approved in mid-December.
If the Planning Commission doesn't side with the group, its leaders plan to take the fight to City Council - and possibly further.
"We'll pursue all of our options," said Dan Martin, the group's chairman and a longtime Broadmoor Bluffs resident. The group has raised $2,800 through a GoFundMe page and more through private donations, though Martin refused to say how much the group has raised or spent.
"We've raised enough money to do what we need to do," Martin said.
Patke, however, says such maneuvering only delays much-needed housing for low-income families amid a severe affordable housing shortage in the Pikes Peak region.
"The neighborhood opposition doesn't want those people in their neighborhood," Patke said. "And that's how they were characterized - 'those people.'"
The dispute centers on a project that local nonprofit leaders hail as a critically-needed first step in addressing the region's affordable housing shortage.
The $14 million development aims to create three apartment buildings on a vacant lot behind a Safeway grocery store at South Academy Boulevard and Colorado 115.
Greccio Housing - a nonprofit that oversees hundreds of affordable housing units across Colorado Springs - partnered with Wisconsin-based Commonwealth Development Corp. on the project.
It was notable for a financing model that included low-income housing tax credits approved by the Colorado Housing and Finance Authority. The specific type of tax credit - the most generous offered by the agency - had not been awarded here for units catering to low-income families since 2004.
In that time, such credits were given for senior housing or assisted living projects. Another project in Colorado Springs, the Greenway Flats development on Springs Rescue Mission's campus, also received the same type of credits the same day as The Ridge in 2016.
One-, two- and three-bedroom apartments are planned for people earning between 30 percent and 50 percent of the area's median income. For example, the most a family of four could earn and still apply for an apartment is about $35,500 a year.
It also will include all the amenities of other Greccio-managed properties, including vocational coaching programs, financial and child literacy classes.
About three months after Greccio announced plans for the project, opposition arose in the surrounding community - much of it focused on fears that the project would devalue neighbors' homes, overwhelm nearby schools and inundate streets with traffic.
Hundreds of people showed up at community meetings last winter that stretched for hours as residents voiced near unanimous opposition to the project.
One Broadmoor Bluffs man asked why the project should come "on the backs of those who are more fortunate?" And repeatedly, neighbors mused "Why here?"
The few Broadmoor Bluffs residents supported the project publicly and privately criticized their neighbors for a "not in my backyard" stance.
Many of the comments that poured into the city's planning office carried that adverse tone, with existing homeowners worried about low-income families moving into the community, said Hannah Van Nimwegen, the city planner overseeing the project.
The focus of many of those letters shifted in spring 2017, however, toward concerns about city codes, zoning regulations and geological evaluations of the land, she said.
The developer, Commonwealth, said such opposition isn't unique to the Broadmoor Bluffs area, and that infill projects have historically been met with concerns by surrounding residents.
"Our plan is to see it to the end," said Daryn Murphy, Commonwealth's vice president of development for its northwest region.
The company initially planned to break ground on the project in May or June 2017, with tenants moving in as early as June 2018.
That never happened, and it won't for the foreseeable future.
Martin says that's indicative of elemental flaws in the project's design.
City planners "effectively" removed the property from the city's Hillside Overlay, Martin claimed in his appeal, adding that they did so without rezoning the property as would be needed.
The appeal alleges city code violations, including one overseeing the building's height. It claims the proposal violates the federal Americans with Disabilities Act by not having proper access routes. And it claims the building's construction could endanger nearby properties due to the area's unstable soil and propensity for landslides.
Van Nimwegen, the city planner, defended her decision in a recent report to the Planning Commission ahead of its hearing.
For example, she said the property was never removed from the city's Hillside Overlay, and that a key assessment - a land suitability analysis - was not needed, because the land had already been graded as part of a failed condominium project roughly 10 years ago.
She pointed out that a sidewalk won't be constructed along the apartments' proposed access road because it exists on private property owned by the nearby Las Casas Condo Owners Association.
The nonprofit and developer conducted a traffic study, even though none was required. And the project will adhere to the city's new landslide regulations passed in early 2017, even though planning for it began before the new ordinance passed, she said.
"We were reviewing the project just like any other multifamily project," Van Nimwegen said. "We looked at the hillside ordinance, we looked at the zone district, we looked at the master plan and everything is according to code."
Martin disputes that.
"They made their decision," said Martin, of city planners. "They knew it was going to be contentious. They knew we were going to challenge it."
"The planning commission gets to decide," he added.