DEPARTMENT: Planning Department
DEPARTMENT HEAD: Bridgett White, AICP
COUNCIL DISTRICTS IMPACTED: Citywide
SUBJECT:
Possible amendments related to the “MF-33” and “MF-25” zoning districts as part of recently adopted Comprehensive Land Use Categories.
SUMMARY:
A briefing on a Council Consideration Request by Councilman Robert Treviño to bring forward amendments related to the “MF-33” and “MF-25” zoning districts as part of recently adopted Comprehensive Land Use Categories.
BACKGROUND INFORMATION:
On October 11, 2018, City Council approved amendments to City Code Chapter 35, Unified Development Code (UDC) to update the City’s Comprehensive Land Use Categories and associated Definitions and Rules of Interpretation. This update provides categories that enable the City to implement the Comprehensive Plan (including better defined mixed-use categories); provides categories that generally align with existing land use plans; and creates a consistent, predictable, and well defined classification for application across the entire City.
The Land Use categories and associated permitted Zoning Districts are outlined below:
|
Land Use Categories |
Permitted Zoning Districts |
|
Residential Estate |
FR, R-20, RE, and RP |
|
Low Density Residential |
R-4, R-5, R-6, NP-8, NP-10, and NP-15 |
|
Urban Low Density Residential |
R-3, R-4, R-5, R-6, RM-5, RM-6, MF-18, MH, MHC, MHP, and NC |
|
Medium Density Residential |
R-3, R-4, RM-4, RM-5, RM-6, MF-18, MF-25, MF-33, MH, MHC, and MHP |
|
High Density Residential |
RM-4, MF-25, MF-33, MF-40, MF-50, MF-65, MH, MHC, and MHP |
|
Neighborhood Commercial |
O-1, NC, and C-1 |
|
Community Commercial |
O-1.5, NC, C-1, and C-2 |
|
Regional Commercial |
O-1.5, O-2, C-2, L, and BP |
|
Neighborhood Mixed-Use |
RM-4, RM-5, RM-6, MF-18, O-1, NC, C-1, MH, MHC, MHP, FBZD, AE-1, and AE-2. |
|
Urban Mixed-Use |
RM-4, RM-5, RM-6, MF-18, MF-25, MF-33, MF-40, O-1, O-1.5, C-1, C-2, MH, MHP, MHC, FBZD, AE-1, AE-2, AE-3, and AE-4 |
|
Regional Mixed-Use |
MF-33, MF-40, MF-50, MF-65, O-1.5, O-2, C-2, C-3, D, ED, FBZD, AE-1, AE-2, AE-3, and AE-4 |
|
Employment/Flex Mixed-Use |
RM-4, MF-18, MF-25, MF-33, O-1, O-1.5, C-1, C-2, L, AE-1, AE-2, AE-3, and AE-4 |
|
Business/Innovation Mixed-Use |
RM-4, MF-18, MF-25, O-1.5, O-2, C-2, C-3, L, I-1, MI-1, BP, AE-1, AE-2, AE-3, and AE-4 |
|
Light Industrial |
L, I-1, MI-1, and BP |
|
Heavy Industrial |
I-1, I-2, MI-1, MI-2, QD, and SGD |
|
Agricultural |
RP and FR |
|
City/State/Federal Government |
n/a |
|
Parks/Open Space |
n/a |
The categories were developed with input from community groups including not-for-profit organizations, neighborhood coalitions, external governmental stakeholders, development industry representatives and affected city departments. In addition, input was received from City Council offices and six community meetings held throughout the update process.
ISSUE:
After submittal of the October 11, 2018 CCR, the Mayor’s Office convened District 1 and District 7 along with Planning Department staff to better understand the issues outlined in the CCR.
Removal of the “MF-33” zoning district from the Medium Density Residential Category
During these meetings, District 1 staff raised three issues related to its proposal to remove the “MF-33” zoning district from the Medium Density Residential land use category:
1. Isolated, mid-block, and small clusters of parcels zoned “MF-33” (due primarily to past zoning code conversions) that are located in areas generally zoned to single family uses. The potential height and scale of new developments on these “MF-33” parcels could be considered to be out of context with the surrounding area.
2. Portions of Downtown and Westside neighborhoods are shown with Medium Density Residential in very early draft land use maps for these Sub-Area Plans. Allowing up to “MF-33” densities and height in these neighborhoods could be considered to be out of context with the surrounding area. In addition, some of these neighborhoods include some areas with blocks of RM-4 parcels, creating a concern that they would have to be categorized as Medium Density Residential because RM-4 is not currently a permitted zoning district in the Urban Low Density Residential land use category. The related concern is that these parcels will be non-conforming if these areas are designated as Urban Low Density Residential.
3. Areas on the near Westside (particularly along the Zarzamora corridor) with smaller parcels that will likely be re-zoned to “R-1” or “R-2” upon adoption of the proposed UDC revisions to Section 35-310.05(a) “Single Family Residential District” are shown as Medium Density Residential on the very early draft land use map for the Westside Community Area Plan. In aggregate, these parcels could result in densities ranging from 21 to 35 units per acre which could indicate the need for a Medium Density Residential land use designation.
Addition of the “MF-25” zoning district to the Neighborhood Mixed-Use Category
The Neighborhood Mixed-Use land use category currently has “MF-18” as the maximum density residential zoning district. The maximum residential density should be increased to “MF-25” to encourage greater density and transit-supportive land use along neighborhood corridors, particularly those with transit service.
ALTERNATIVES:
The alternative to the specific CCR request is that no UDC amendments would be made and the land use categories adopted on October 11, 2018 would remain unchanged. Alternative solutions to the issues listed above are found in the “Recommendation” section below.
FISCAL IMPACT:
There is no fiscal impact associated with this briefing.
RECOMMENDATION:
Removal of the “MF-33” zoning district from the Medium Density Residential Category
The Planning Department does not support the CCR request to remove the “MF-33” zoning district from the Medium Density Residential land use category.
The stated goals and policies of SA Tomorrow and the adopted Comprehensive Plan support increased density and intensity in our City’s urban centers and along key corridors (particularly those with existing or planned rapid transit service), while limiting density changes to appropriate levels in established neighborhoods. The future land use plans emerging from the Sub-Area planning process must successfully guide the City’s growth and evolution over the next 10 to 20 years. Previous land use plans that capped the Medium Density Residential category at “MF-18” were created prior to SA Tomorrow and do not reflect the adopted Comprehensive Plan’s goals, nor the urgent needs to grow in a fiscally and environmentally sustainable manner by accommodating and supporting greater density in appropriate areas, promoting housing affordability through greater supply, and creating a wider range of housing options within our existing urban footprint.
San Antonio is not alone in facing the challenges of population growth and decreasing housing affordability; nor is it unique in responsibly directing greater densities of new housing and jobs to targeted, appropriate areas. In comparison to other growing peer cities (Austin, Dallas, Seattle, Portland, and Minneapolis), San Antonio caps the Medium Density Residential land use category at the lowest end of the collective range. Medium Density Residential categories in these peer cities allow maximum densities ranging from 35-65 dwelling units per acre, compared to San Antonio’s just adopted maximum of 33 dwelling units per acre.
The issues raised and clarified by District 1 in subsequent discussions can instead be addressed with the alternative solutions outlined below.
1. The most effective and expedient approach to addressing isolated, mid-block, and small clusters of “MF-33” parcels in specific neighborhoods is through zoning, not by adjusting land use categories intended for use throughout the entire City. Two possible approaches to resolving these concerns are: (1) Re-zone these “MF-33” parcels; and (2) Review of the ordinance dictating the application of height allowances allowed under “MF-33” zoning when in proximity to single-family zoned parcels (UDC section 35-317).
2. The Planning Department continues to meet and work with the Southtown neighborhoods to determine appropriate future land use designations, and anticipates that with the exception of parcels abutting key corridors like St. Mary’s, Presa, and Probandt, most parcels will be designated as Urban Low Density Residential in these neighborhoods once the sub-area planning process and land use maps are finalized.
In the case of parcels in these areas that are currently zoned “RM-4”, there are two realistic strategies that can be employed: (1) Upon completion of the Downtown Regional Center Plan, the Planning Department’s dedicated zoning staff can work with property owners to re-zone “RM-4” parcels, as appropriate, to one of the allowable zoning districts conforming with the Urban Low Density Land Use designation; and/or (2) the Planning and Development Services Departments together can explore and propose UDC revisions to the “RM-4” zoning district (as requested in District 1’s August 2017 CCR) to ensure it functions as originally intended, then add “RM-4” back as an allowable zoning district in the Urban Low Density Residential land use category during the 2020 UDC update process so the parcels are no longer non-conforming with the designated land use.
3. The Urban Low Density Residential land use category was created to provide an appropriate land use context for a number of areas inside Loop 410, including many of the near Westside neighborhoods that have parcels smaller than 3,000 square feet and that historically have had small, locally-owned, neighborhood businesses embedded within the neighborhood fabric. Urban Low Density Residential will likely be the appropriate land use designation for many general neighborhood parcels on the Westside, east of 19th Street.
In addition, the Planning Department anticipates that only parcels within one to three blocks of the Zarzamora corridor (or designated rapid transit stations) will be designated to Medium Density Residential or Neighborhood Mixed-Use (depending on the context) in order to encourage land uses supportive of the important investments VIA Metropolitan Transit is making on the Zarzamora rapid transit route. These designations will be finalized as part of the sub-area planning process which includes neighborhood association and resident input.
Addition of the “MF-25” zoning district to the Neighborhood Mixed-Use Category
The Planning Department supports the request to add the “MF-25” zoning district to the Neighborhood Mixed-Use land use category.
This addition would provide a wider range of options for developing the vibrant urban centers and corridors called for by the SA Tomorrow Comprehensive Plan by facilitating additional housing supply, and supporting higher quality transit, retail options, and services.
The Planning Department did not receive any specific public comments related to the inclusion of “MF-25” in the Neighborhood Mixed-Use land use category during the public input process previously outlined. We recommend moving forward with a process to explore this proposed change as part of the 2020 UDC update process, or as a separate City Council action prior to the 2020 update. In either case, the process should allow for public review and comment on the matter, including review by the Planning Commission’s Technical Advisory Committee, the Planning Commission, and the Zoning Commission before consideration and approval by the City Council.