The county’s planning director said she could not tell whether a 74,000-square-foot travel center is a “convenience store.” Buc-ee’s, on appeal, insists that it is. Now the opposition has filed a third answer: it is neither undefinable nor a convenience store, but something El Paso County’s code already names — a truck stop. A 29-page analysis released July 15th by Tri-Lakes Preservation, Inc. works through the county’s own classification criteria and lands on the one label Buc-ee’s has spent this fight avoiding, because a truck stop cannot be built on Monument Hill without a rezoning.
Tri-Lakes Preservation, the Monument-based preservation group that has opposed the project since its Palmer Lake annexation days, published the report on its website and, in a press release, said the analysis “will also be submitted to the BoCC and PCD as evidence for the hearing.” The Board of County Commissioners will hear Buc-ee’s appeal of the county’s July 1st non-determination — county file APP261 — on a date not yet set.
The report enters a dispute this newspaper has followed from the beginning: Buc-ee’s June request to have its proposed 31-acre travel center — 74,000 square feet of retail and restaurant space, 120 fueling positions, 20 EV chargers and 812 parking spaces — classified as a “convenience store”, the only fuel-selling use allowed in the site’s obsolete C-1 zoning; the planning director’s answer that the county could not make that determination; and the company’s appeal to the elected board.
Two Questions, Two Nos
The analysis is organized around the two questions the commissioners must answer. Does the travel center meet the code’s definition of a convenience store? And if not, does it meet the Land Development Code’s Section 5.3.6 criteria to be treated as “similar” to one in a C-1 zone?
On the first, the report leans on the definition’s opening clause: a convenience store exists “for the purpose of offering for sale to the neighborhood in which it is located” its groceries, ready-to-eat food and sundries. The county’s own Master Plan, it notes, designates the Monument Hill site ”suburban residential,“ where commercial uses “must be small-scale standalone businesses that serve a neighborhood population.” Against that yardstick the report stacks the project’s arithmetic: a store 30 times the size of the average American convenience store and roughly four times as large as every existing convenience store in the Tri-Lakes combined; a fuel canopy that would nearly double the passenger-vehicle gas pumps in the entire area; and the company’s own statement to Palmer Lake that 90 to 95 percent of its sales come from customers outside the zip code where a store sits. For the project’s expected 22,150 daily vehicle trips to come from the neighborhood, the report calculates, each of the Tri-Lakes’ 8,750 households would need to visit more than two and a half times a day.
On the second question, the report attacks the comparison at the heart of Buc-ee’s appeal. To show its traffic would be no worse than other C-1 development, the company modeled three alternative build-outs of the site — a 304,500-square-foot shopping center, a 245,000-square-foot supercenter complex, and a 9,000-seat indoor concert venue. None of the three, the analysis observes, is actually an allowed use in a C-1 zone: shopping centers are listed in other commercial districts (and thereby excluded from C-1), and a 9,000-seat arena would not fit under the zone’s 30-foot height limit — the Broadmoor World Arena’s interior alone rises 79 feet. Meanwhile the applicant’s own trip figures put the travel center at nearly seven times the daily traffic of an actual convenience store with gas pumps. By the report’s count, the impacts follow the same curve: 260 exterior lights, against 80 at the Falcon King Soopers, and a building atop a 30-foot retaining wall that would present a 60-foot face to Interstate 25, reflecting highway noise toward Woodmoor.
The Truck-Stop Pivot
Where the county stopped at “cannot determine,” the report keeps going. Of the three fuel-selling uses the code defines — gas station, truck stop, convenience store — it finds the truck stop nearest the mark: “large-scale facilities that serve highway travelers” with fuel, retail and food service. The definitional gap is that the county’s truck stop serves commercial drivers, while Buc-ee’s famously bans 18-wheelers; the report answers that the company sells diesel to the smaller commercial vehicles it does admit, and that the banned truckers may still park elsewhere and shop. Run through the same Section 5.3.6 similar-use test that Buc-ee’s invokes, the report concludes a travel center passes as a truck stop: consistent with the purpose of the Commercial Services zone where truck stops are allowed, and similar in traffic, parking, lighting, fuel storage and 24-hour operation.
The recommendation’s teeth are in the zoning table. Truck stops are a special use, allowed only in three districts — none of them C-1. Classifying the travel center as one would mean the Monument Hill site could not host it without a rezoning, and the special-use process would add a public hearing focused on traffic, harmony with the neighborhood and health risks. That is the same destination the county pointed to in 2024, when its early-assistance review told the company to rezone and to demonstrate a 300-year water supply. The report frames the convenience-store request as the latest step in a “piecemeal” strategy to avoid that path — an argument Tri-Lakes Preservation first made in an earlier analysis this newspaper has covered. If the board will not adopt the truck-stop label, the report offers a fallback: amend the code to define “travel center” outright, as a special use in the county’s large-scale commercial zones.
An Advocate’s Analysis, Aimed at the Record
Tri-Lakes Preservation opposes the project; its tagline is “Preserve Now or Lose Forever!” and its release closes by thanking supporters working to “Heave the Beave.” The analysis is advocacy, and reads as a direct rebuttal brief to Buc-ee’s appeal. But it is a documented one — its 20 references run from the county’s EDARP files and Land Development Code to the Master Plan, the assessor’s rolls and the 2021 Monument community survey — and it supplies what the proceeding has so far lacked: a worked answer to the question the planning director left open and the more than 80 objecting residents posed less formally. It joins a broader opposition infrastructure that includes the group’s Stop Buc-ee’s campaign and Integrity Matters, whose commissioner surveys and campaign-finance work this newspaper has drawn on before.
The commissioners now have three theories before them. Buc-ee’s says the code, read literally, makes the project a convenience store. The planning director says the county cannot say what it is. And the opposition says the code has known what it is all along — it just is not allowed on Monument Hill. The hearing, whenever it is set, will decide which reading survives contact with a vote.
Sources & Method
- Tri-Lakes Preservation, Inc., “Use Determination for Travel Center on Monument Hill — An Independent Analysis” (final, July 14, 2026; released July 15, 2026) and accompanying press release (July 15, 2026).
- El Paso County EDARP: ADM264 (Determination of Use) and APP261 (appeal to the BoCC, filed July 2, 2026; no hearing date set as of publication).
- El Paso County Land Development Code, Table 5-1 (principal uses) and §§1.15 (definitions), 4.1.4 (obsolete districts), 5.3.6 (similar-use criteria).
- El Paso County, “Your El Paso” Master Plan (2021), suburban residential placetype.
- Tri-Lakes Preservation, “Why a Convenience Store?” (earlier analysis, opposition).
- Prior reporting: Buc-ee’s Tries the Back Door · Eighty-Plus Objections to Buc-ee’s, Filed “for Reference Only” · Is a Buc-ee’s a “Convenience Store”? The County Says It Cannot Tell · Buc-ee’s Appeals — and the Question Lands with the Commissioners · Follow the Money.
- Method note: figures for the proposed project (74,000 sq ft; 120 fueling positions; 812 parking spaces; 22,150 daily trips; 260 exterior lights) are as stated in the Tri-Lakes Preservation report, which draws them from Buc-ee’s own application, appeal and traffic materials; characterizations of the project’s fit with county definitions are the report’s. The Monument Independent has not independently verified the report’s calculations.