Government Hill resident’s comments at City Council re Zoning Change from R-6 to C-2 in a residential neighborhood on why we fight for our communities.

Written by D’Ette Cole of Government Hill

Note: On November 5th City Council (A Session) meeting Government Hill residents gathered with white COVID masks on which were printed, “C-1”.  They were there, after so many postponements to ask City Council to reject a zoning change from R-6 to C-2 in their residential neighborhood and to accept instead a compromise of C-1, a fair compromise that they were struggling to have approved. 

Read about the case at the SA Heron

Good morning, 

We hope good prevails today. We have a compromise for C-1 on the property which sits just 24′ across the street from our homes.  We hope that if any motion for higher than C-1 light commercial is introduced that you will not entertain it, you will not support it, and that you will be a protector and a proponent for community compromise and our 200′ neighbors’ compromise for c-1.

This has been a long pursuit which began over a year ago when we first got word that the property at the corner of Reno and Edgar street was going to be sold and that the longtime neighbors would be removed and the six houses  leveled for a twenty-pump mega gas station a zoning change from an almost unheard of R-6 (residential) to C-2 (intense commercial).  It seemed incredible that affordable housing would be demolished and we would be living across the street from a huge gas station. We did not know where to begin to fight.

First the case would have to go through the rezoning process to get rezoned from R-6 to C-2 commercial. Not imagining how this huge project could be plopped down in our tiny neighborhood immediately in front of our homes and so close to an elementary school, the 200′ neighbors banded together to show and tell the city that there must be some mistake.  

Ours is a predominantly Latino, multi-generational, working class neighborhood. Several of the 200′ neighbors who have called this neighborhood home for decades,  said I didn’t understand: No one will care, no one will listen,  and we won’t win because we never win – we don’t matter. Before this process was over, I began to understand why they felt this way. 

With the overwhelming opposition to this encroachment within the 200′ and blocks beyond, we organized and pushed on but there are group members who do not access the internet, that are not computer savvy, or would never be able to stand and speak here. There are those in our group that you have not seen because they cannot come to commissions or hearings due to health issues or because of their essential jobs, especially now with COVID.  

Home. 

This is home. We love our homes and are extremely house proud and though the story of how and when we each came to call this neighborhood our home is different from each of our neighbors – We all have stories of dreams and desires of inherited homes passed down, full of fond childhood memories:

Neighbors like Dora and Martin whose first homes with first mortgages bring the swell and pride of ownership in our community. 

Neighbors like Addie and Caleb who have lived in their well-loved home for decades with adult children who have moved back in to care for ailing elders. 

Roxanne and Aden, starter homeowners with hopes of future kids walking to the elementary school down the street. 

Jazzma and Armando, retirement homeowners looking to downsize. 

Lorenzo and Virgina, purchasing and refurbishing a small house on the top of hill with a million dollar view of the downtown skyline. 

These are some of our neighbors.  

These homes, these neighbors, these streets, our elementary school, and our park are a lot to fight for. 

Our community has been worth every second, every meeting, pow wow, late night group call, every Sunday afternoon driveway meeting, every block walked, every signature collected, every email sent, every phone call, every educating and telling of details, every sign designed and every sign hung, every sleepless night, every tear shed and every new worry wrinkle. 

Everything has been worth it because this fight has been about our homes and our neighborhood. 

This process has been extremely intimidating and consistently disappointing.  Our neighborhood and our homes have been publicly  disparaged in descriptive terms like “derelict, crime ridden, crime stricken, drug and graffiti infested, unsafe and scary” by those who should know better, by a member of the Zoning Commission, by attorneys, by those who want to profit from our neighborhood.  

We’ve been ignored, we’ve been dismissed, we’ve been excluded, we’ve been insulted, disparaged, berated and basically told to be quiet.  We would not stay quiet.

We love our neighbors, we love our neighborhood, we love our city so we cannot be blamed for fighting so hard for the best outcome for this block that impacts us all so significantly.  Despite it taking such a long time to get here, we look forward to a true C-1 compromise.   A C-1 light commercial project that will be an appropriate buffer between the C2-NA Frost property on the access road and our dense residential front yards.  A neighborhood friendly C-1 development that will be the appropriate scale and setting to meet our residential and school zone streets.

Council representatives: I couldn’t and I wouldn’t do the job that each of you has signed up for and run and won to do.  I thank you for having the will and for wanting to make a difference, to make things better, do better, and do good.  Please never underestimate the power of listening and understanding,  conversation and collaboration and compromise – this fight would have been more civil, more fair, less hurtful, less marginalizing, and better for it.

Please support the 200′ neighbors C-1 compromise for this case.

Additional Information: MF/RM UDC Amendments to Help our Neighborhoods

Read: The latest MF/RM UDC Recommendations released from DSD (11/19)

Read: T1NC’s Letter to the Mayor re MF/RM UDC Amendments

Background (excerpt from August 21, 2017 CCR):

Councilman’s CCR – full text

“Over the past two years, there have been a growing number of RM-4 and MF-33 housing developments which have caused much concern throughout our communities. Currently, the UDC designations for these codes allow for construction up to 35 feet in RM-4 and 45 feet in MF-33, with no specifications that the units allowed must be contained within a single structure.

This has caused an influx of developments or proposed developments to build four or more 2- 4 story single units on a single lot within a residential neighborhood, which ultimately is incompatible and highly impactful development.

City staff and the zoning commission have discussed and recommended denial for cases where IDZ infill was not appropriate, but where the base zoning of MF-33 or RM-4 allowed them even more density or development, which caused a conflict of ideas and put impotence [sic] on these decisions.

As a result, the community feels unprotected and the lack of notification and input required for development without a zoning change have led to concerns and fear of developments occurring “overnight” without consideration for the surrounding community. Development in our city is occurring at a rapid rate, and our citizens are turning to Historic Designation and NCDs as they perceive this to be their only option. However, these options ultimately do not regulate use of the property, or density, as designated by the zoning and therefore does not address the real issue at hand.”

The main issues this task force was meant to address were:

1. Height

2. Multiple units contained in a single structure

3. Neighborhood notification and input

Often when multiple structures sold as “single-family homes” are proposed (versus multiple units contained in a single structure), developers say they are encouraging homeownership. However, we have found that the stand-alone units are being used as luxury rental housing, regardless of being sold as a single-family condo.

Below are several examples of both new, incompatible multiple-structure RM-4 developments, and traditional, compatible, single-structure RM-4 properties. As you can see, containing multiple units in a single structure is both common, and architecturally diverse. There is no need to be concerned that this requirement, which is the traditional form for missing-middle housing, would create “monolithic” structures.

Multiple Incompatible Structures on one lot:

W Craig in Beacon Hill, zoned RM-4
Fulton Ave. in Alta Vista, zoned RM-4

Traditional, compatible single structures with multiple units:

Fulton Ave. in Alta Vista, zoned RM-4
Fulton in Alta Vista, zoned RM4
Fulton Ave. in Alta Vista, zoned RM4
E Huisache in Monte Vista, zoned MF-33

“Missing Middle Housing” offers Compatibility with Single-Family Development Pattern

These diagrams from http://missingmiddlehousing.com show yellow missing middle housing mixed
with one- and two-story neighborhood “typical” single-family homes. Above is a typical T3
neighborhood (similar to many in San Antonio) with the missing middle housing and single family
mixed throughout the neighborhood.
This diagram – the white buildings toward the left are the one- and two-story neighborhood “typical”
single-family homes. The Missing Middle Housing buildings, in yellow, are shown to provide a transition
to the more urban “main street” with live-work and commercial buildings and uses. The compatibility
of multifamily buildings that are similarly scaled and massed (i.e.: contained in one structure) to the
single-family is more widely accepted as compatible.

T1NC’s Letter to Mayor re MF/RM UDC Amendments

Read Background and Important Additional Information

Read the latest draft from DSD of the MF/RM UDC Recommendations.

 November 22, 2019

Dear Mayor Ron Nirenberg, 

On December 5, City Council will be considering a proposed Ordinance adopting changes to Chapter 35 of the Unified Development Code (UDC), specifically Section 35-310-01 and Table 310-1 Lot and Building Dimensions Table, relating to Lot and Building Dimensions in “RM” and “MF”. 

The changes proposed by DSD were recommended for approval by the Planning and Zoning Commissions.  We support the clarification added by the Planning Commission Technical Advisory Committee (PCTAC) limiting building height to 35’/2.5 stories for MF-33 properties under 1/3rdacre. However, we ask that the amended language recommended by the Zoning Commission regarding vacant lots be stricken. 

The new wording proposed by the Zoning Commission will incentivize further demolitions in our neighborhoods. If a MF-33 lot is on a corner, and the lot next to it is a vacant (undeveloped) lot that is zoned for single family, the MF-33 could be built up to 45-feet high, because the vacant lot is not being used as a single-family home. If someone were to purchase both properties, they could have any structure on the single-family lot demolished in order to gain the additional ten feet in height by-right.If there is a vacant lot, the use should be assumed to be in line with its zoning, not a hypothetical school or church. We should be starting from the most conservative answer, not the most extreme. 

We appreciate the hard work this task force has done on the proposed changes, however we feel the recommendations are not as complete as they could be. The CCR issued in 2017 by Councilman Treviño was created with the intent to address neighborhood compatibility issues. I ask that you read through the CCR. The main issues this task force was intended to address were: 

  1. Height
  2. Multiple units contained in a single structure (massing)
  3. Neighborhood notification and input

With this focus in mind, I ask that you approve the changes being proposed today with the following amendments:

To address height: 

  • Remove the wording proposed by the Zoning Commission regarding vacant properties in Note 11. 
  • Adopt the clarification provided by PCTAC on Note 11. 
  • Amend Table 310-1 to reflect 35’/2.5 storiesallowing exceptions based on PCTAC’s clarification of Note 11. 
  • Table 310-1: the placement of Note 11, which addresses height, should be moved from the header of the table to the first column for each zoning category. This will align the placement of the note to match the rest of the table lending clarity to all who use the table in the future.

To address massing and neighborhood notification and input:

  • 35-310.01(c): Amend language from “must occur within a completely enclosed structure” to read “must occur within a single completely enclosed structure” so that it reads: “Unless expressly permitted as an accessory use, a use permitted in the “RE,” “R-20,” “R-6,” “R-5,” “R-4,” “RM-6,” “RM-5,” “RM-4,” “MF-18,” “MF-25,” “MF-33,” “MF-40,” or “MF-50” districts must occur within a singlecompletely enclosed structure.” This will address the concern over multiple structures.
  • 35-310.06(a)(1)(b): Insert, “which shall be contained in a single structure” at the end of the sentence so that it reads, “The maximum number of dwellings is limited to two (2) units for RM-6, three (3) units for RM-5, and four (4) units for RM-4, which shall be contained in a single structure.” This will further address concerns over multiple units being attached. 

These two changes that address massing will also help address the third concern over neighborhood notification. If a property owner wishes to develop their site with a different massing, they would be allowed to go before the Board of Adjustment (BOA). The BOA process is public and would trigger the public notification.  

Please note that the traditional development pattern for RM-4 and MF-33 has consistently been to have multiple units in one single structure. There are numerous examples of this architecturally rich missing-middle housing throughout our neighborhoods.  Please see second attachment.

These amendments would help address the concerns over compatibility of these zoning categories in our neighborhoods. 

Thank you for serving our community.

Tier One Neighborhood Coalition Steering Committee

Cosima Colvin, Christine Drennon, Liz Franklin,Tony Garcia, Jordan Ghawi, Mary Johnson, Ricki Kushner, Margaret Leeds, Alan Neff, Velma Pena, Monica Savino, Anisa Schell, Cynthia Spielman, Amelia Valdez, Theresa Ybanez

Mayor and City Council Members:

Mayor Ron Nirenberg ron.nirenberg@sanantonio.gov

D1 Roberto Trevinoroberto.trevino@sanantonio.gov

D2 Jada Andrews-Sullivan Jada.andrews-sullivan@sanantonio.gov

D3 Rebecca Viagran Rebecca.Viagran@sanantonio.gov

D4 Dr. Adriana Rocha Garcia Adrianarocha.garcia@sanantonio.gov

D5 Shirley Gonzales Shirley.Gonzales@sanantonio.gov

D6 Melissa Cabello Havrda Melissacabello.havrda@sanantonio.gov

D7 Ana Sandoval Ana.Sandoval@sanantonio.gov

D8 Manny Pelaez Manny.Pelaez@sanantonio.gov

D9 John Courage John.Courage@sanantonio.gov

D10 Clayton Perry  Clayton.perry@sanantonio.gov

BHANA’s Letter to Mayor re Development Regulations Review CCR

Read: “The CCR that Prevents Meaningful Citizen Input” , the Development Regulations Review CCR, the UDC Amendment Process and Timeline

Note: This letter is based on the T1NC template letter. We added specific details about our neighborhood in the second to last paragraph. Please feel free to use this as a template by deleting that paragraph or changing it to details about your community.

November 14, 2019

Re: CM Pelaez CCR “Developmental Regulations Review” 

Dear Mayor Nirenberg, 

We are writing to respectfully request that you vote against to the “Development Regulations Review” CCR that would require an economic impact analysis to accompany any proposed amendments for the 202 UDC review. It will come before City Council for adoption in December 2019 for a vote.  

If passed, this ordinance would put an undue burden on residents and community groups wishing to submit any code amendments or participate in the 2020 UDC updates. It is important to include the input from community and advocates to create a balance between developer interests and community and neighborhoods. This balance is necessary in moving forward to meet the challenges of the future. 

Groups “outside of DSD” do not have the resources to provide an economic impact assessment, particularly groups that have been (and can be argued still are) marginalized in the past. This is an unreasonable burden to place on your engaged and concerned constituents. The UDC review process should be inclusive and accessible by all of our citizens as well as adhere to the Public Participation Principles that Council adopted last year. 

The expectation that San Antonio’s UDC recommendations should be limited to only those that would make development more profitable is a very narrow lens by which to view our City’s progress.  Development and its effects, both positive and negative, is a complex issue and needs input from all stakeholders in order to make informed decisions. Costs to developers is already a factor that is considered when adopting amendments; codifying it would serve no purpose except to severely limit public input. 

Our neighborhood of Beacon Hill has been one of the downtown neighborhoods that has changed. We have witnessed displacement, demolition of homes, incompatible development, and skyrocketing property taxes. We have also enjoyed the revitalization of the Blanco Road shopping corridor (and hope to repeat on Fredericksburg Road), the welcoming of new and engaged neighbors, and the repair to neglected properties. We understand that in order to meet the challenges of the future, we must perform a balancing act. We promote compatible, affordable, and sustainable housing and the revitalization of our commercial corridors; we promote the preservation of our unique and historic housing stock; and we seek to protect our legacy neighbors, particularly the most vulnerable, from displacement. In order to achieve these goals, Beacon Hill, along with the other neighborhoods, needs to have a part in the decision-making process. We need to be able to advocate for sensible and fair UDC amendments. 

Please stand up for public citizen participation and support your constituents’ voices by voting against the Development Regulations Review CCR.  

Thank you, 

Beacon Hill Area Neighborhood Association

The CCR that Prevents Meaningful Citizen Input

Read: Op-Ed in the Express-News

Update: D8 Councilman Pelaez met with T1NC members and then issued a formal memo to Department of Development Services (DSD) that states, in effect, that anyone submitting an external UDC amendment will not have to to the cost analysis.

Read Councilman Pelaez’s CCR Memo to DSD address the issues here.

What are the Unified Development Codes (UDC)?

The Unified Development Code (UDC) is extremely important to the residents of San Antonio as  these codes guide development in our city and neighborhoods. These codes determine such things as how high a building can be constructed in the middle of a one and two story residential street to storm water reviews that are triggered when projects are built. The UDC deals with issues of parking, short term rentals, zoning and permitted uses. These codes are now being reviewed with requests for amendments due by May 1, 2020: UDC Amendment process and timeline available here.

The people who live in San Antonio are directly affected by these codes and how they are amended. 

What is the CCR?

In November 14, 2018, Councilman Pelaez submitted a Council Consideration Request (CCR) which is the first step in creating an ordinance. It was signed by councilmembers from Districts 1, 3, 5, and 10.  The CCR, “The Development Regulations Review,” requires that amendments to the UDC must have an “economic impact analysis” to determine if the request costs developers more money, less money, or has no monetary impact at all. The “economic impact analysis”  must then be approved by the Planning Commission Technical Advisory Committee (PTAC) and the Planning Commission.  As part of the impact, the following items must be considered and documented: initial and long‐term maintenance costs; city cost (i.e. personnel costs and costs to enforce); Indicate and be able to rationalize the baseline (current costs) and the cost projections associated with the request.

Why this CCR restricts input from residents and advocates:

This requirement for an “economic impact analysis” is a barrier to public participation in that it places an onerous burden on citizens recommending code amendments. This requirement, which could soon be adopted by City Council in December 2019 as ordinance, violates the principles of inclusiveness and transparency as promoted by the Public Participation Principles adopted by City Council last year.

How this CCR is built on assumptions that are not accurate:

The CCR itself is built on the false premise that the City of San Antonio (COSA) has made project development difficult for developers through “recommendations that pertain to regulations on new construction of residences and commercial properties” by the SA Tomorrow Comprehensive Plan, the Housing Commission, and The Mayors Housing Policy Task Force (MHPTF). 

In fact, the Housing Commission goals reflect the goals of production and investment in affordable housing. The SA Tomorrow Comprehensive Plan and the MHPTF actually make building cheaper and easier through land use recommendations, corridor development plans and by building code recommendations. Through the implementation of the Mayors Housing Policy Task Force, code barriers to affordable housing are being addressed.  In addition, CoSA’s tax incentive and rebate programs, as well as their Fee Waiver Program help reduce the cost of development and make this CCR’s concerns seem disingenuous. 

What this CCR is really about:

What is most telling is the CCR accuses those “outside of DSD” as “placing additional pressures on the current review process.” This CCR seeks to relieve those “pressures” by silencing the voices of residents who live in neighborhoods. We are those “outside of DSD.” There are very few advocates outside of DSD that have the money or the staffing to do a cost analysis. For the good of our city, cost to developers should not be the only lens in which we view our UDC amendments. 

Why we can’t look at the UDC amendments through the lens of developer costs:

Development issues affect more than the financial bottom line for development. It also affects  community safety, equitability, and quality of life.  Developer demands, which have been the focus of City policy in the past, have resulted in suburban sprawl, one of the highest instances of income segregation in the country, and have endangered our water sources. Recently, our inner-city neighborhoods have experienced incompatible and expensive housing which has caused displacement, destruction of legacy homes which has destabilized our neighborhoods and communities, and severe flooding. Balance is needed as we move to meet the challenges of the future before we suffer more “unintended” consequences. 

Additionally, CoSA needs to consider, what Jessica O. Guerrero, community advocate and member of the Housing Commission, calls the “social cost impact fees,” which are the “costs related to displacement on the social services and taxes side.”

Developers have the Department of Developmental Services (who is overseeing the amendment process) and CoSA to advocate for their needs.  Who do we have to advocate for preserving our neighborhoods and protecting vulnerable communities except ourselves?  

 Tier One Neighborhood Coalition and others who are concerned about their neighborhoods advocate for compatible development and affordable housing that seeks to stabilize and maintain resilient and culturally-rich neighborhoods and communities.  There will be no balanced and thoughtful approach to the UDC amendment process if Councilman Pelaez’s CCR is adopted by City Council and a prohibitive burden is placed on residents and community groups advocating for the care of San Antonio residents.  This balance is important to a thriving and healthy city as well as to an inclusive and transparent UDC amendment process. 

This CCR will go to Council to be adopted in December. Please write or call your council member and the mayor to request that they do not adopt this CCR as ordinance.

DSD Academy is holding a workshop on the UDC amendment process on Saturday, November 16th at 9 a.m. at One Stop (1901 S. Alamo).

Sources:

Section 35-11(a) of the UDC – the Updated UDC Amendment Request Form with Cost Impact Statements.

Agenda Memorandum File Number: 19-7814 by DSD (Michael Shannon), October 21, 2019 as part of materials for the presentation to PCTAC.

Please attend for more information:

The UDC Amendment Process

For more information and to sign up for updates. DSD will present on the UDC amendment process for neighborhood groups and organization. Contact Tony Felts, Policy Administrator (210) 207-0153 and Monique Mercado, Senior Planner (210)207-5016 for more information.

What is the Unified Development Code (UDC)?

The Unified Development Code (UDC) is extremely important to the residents of San Antonio because these codes guide development in our city and neighborhoods. These codes determine such things as “subdivision platting, zoning, street and drainage design standards, historic preservation, and protection of natural resources – trees, aquifer, etc.” The UDC deals with issues of parking, short term rentals, zoning and permitted uses. The UDC is updated every five years. 

The people who live in San Antonio are directly affected by these codes and how they are amended. 

The UDC Amendment Process:

These codes are now being reviewed with requests for amendments due by May 1, 2020.  According to the Department of Developmental Services (DSD) which facilitates the process, the amendments are to “modify procedures and standards for workability and administrative efficiency, eliminate unnecessary development costs, and to update the procedures and standards to reflect changes in the law or the state of land use planning and urban design….”

Amendments submitted from outside the city staff, “external” amendments, cannot submit changes unless those changes clarify a provision or edit for grammar or punctuation. The Planning Commission must sponsor any external submission that creates change.  

The Development Services Department (DSD) begins receiving submittals for proposed amendments on January 1, 2020. This year, the DSD has set up a dedicated email address for correspondence related to the UDC Amendment Process as well as UDC Amendment Submittals. That email address is UDCAmendments@sanantonio.gov      

You may also contact Tony Felts, Policy Administrator (210) 207-0153 and Monique Mercado, Senior Planner (210)207-5016

The Path to Approval

 DSD will take submissions, request additional information, conduct “small scale focus groups consisting of industry experts, applicable agencies, and neighborhood leaders, and the development community. (January – May 2020) For applications and instructions go to Sanantonio.gov/DSD

  • Planning Commission Technical Advisory Committee (PCTAC) which advises the Planning Commission will review each UDC amendment that is submitted and make a recommendation. (May – October 2020)
  • From PCTAC, the recommendations are forwarded to the Planning Commission, Zoning Commission, Board of Adjustment (BoA), Historic and Design Review Commission (HDRC), Housing Commission, Parks and Recreation Board.
  • Referrals by these boards and commissions are sent to City Council by December 1, 2020. 

Public Participation

According to DSD, “Throughout the UDC Amendment process, DSD will conduct an extensive community and stakeholder outreach program utilizing the SA Speak Up process, community meetings, social media, constant contact, and the DSD website. DSD will also conduct a comprehensive educational outreach campaign in 2021 after the UDC Amendment process ends in order to educate the community about the new changes to the code, and how those changes may affect  them and their development process. This outreach will be done primarily utilizing SA Speak Up and DSD Academy sessions. We will also utilize social media and constant conduct to advertise the training opportunities.”

Timeline:

January 1, 2020 Amendment submittals begin 

January, 2020 First SA Speak Up Survey gathering input about the UDC Amendment process and providing information on submitting amendments and the amendment process

May 1, 2020 All amendment submittals must be completed

May, 2020 Second SA Speak Up Survey gathering input about the major themes of the UDC Amendments that have been submitted, having the citizens identify their priorities based on the UDC submittals provided, and providing information about the submitted amendments

Mid-May, 2020 PCTAC begins meeting

October, 2020 Third SA Speak Up Survey gathering input about the major themes of the UDC Amendments after PCTAC review, having the citizens identify their priorities based on the UDC amendments and PCTAC process, and providing information about the submitted amendments

October 30, 2020 Amendments forwarded to boards and commissions with PCTAC recommendations for review

November, 2020 Boards and commissions review amendments and make recommendations

December 1, 2020 Boards and commissions recommendations forwarded to City Council

December, 2020 City Council considers amendments

January 1, 2021 All passed UDC Amendments go into effect

January, 2021 Fourth and final SA Speak Up Survey gathering input about the UDC training

January through March, 2021 DSD conducts internal and external trainings and works with Municode to codify amendments. 

UDC Changes since 2015

Since the 2015 UDC Update process, several changes have been made to the UDC as a result of CCRs or Stakeholder Groups. These changes have included:

· Zoning Sign and Courtesy Notice Changes

· Creating the RIO-7 Overlay in the vicinity of San Pedro Creek

· Modifications the demolition procedures for historic structures

· Military Lighting Overlay District (MLOD) update

· Comprehensive Land use Category Updates

· Short Term Rental regulations

· Infill Development Zone (IDZ) update

· Atlas 14 (storm water) update

· Habitat Compliance Form update

Source:

Agenda Memorandum File Number: 19-7814 by DSD (Michael Shannon), October 21, 2019

DSD Academy: UDC 2020. Presentation by Tony Felts, Policy Adminstrator. November 16, 2019 and January 15, 2020.

RM/MF Task Force Updates

The RM/MF Task Force was created in response to Councilman Treviño’s 2017 CCR regarding the municipal code and zoning for residential multi-family properties, specifically zoning categories RM-4 and MF-33. You can view the CCR here. This CCR was filed in response to community concerns over the way lots with these zoning categories are currently being developed. 

These two zoning designations (RM-4 and MF-33) are abundant in our inner core neighborhoods. They are the zoning designations most common for the so-called missing middle housing: duplexes, triplexes, and quadriplexes. They are an important tool for density in our neighborhoods, but in the last four or five years, the way these properties are being developed has changed.  Instead of the traditional duplexes or quadriplexes (two to four units in one structure), we are seeing more and more developments with four individual, tower-type structures on one lot, such as the ones at 930 W. Craig Place. These developments are typically sold as market-rate, single-family homes with some kind of condo-scheme in the title; not really the traditional – or needed – missing middle housing.  

930 W Craig in Beacon Hill – Zoned RM-4

After Councilman Treviño’s CCR was filed, a task force was created. The task force has been meeting monthly over the summer. While I’m not a member of this task force, I have participated in sub-committee meetings, and attended several of the task force meetings as an observer. DSD is facilitating this task force, with Cat Hernandez as the main staff member conducting the meetings.

At the second meeting of the task force, on April 23rd, only three of the appointed neighborhood representatives attended the meeting. They were told that the third and final task force meeting would be the May 28th meeting, but no meaningful changes had been suggested for the pertinent codes. The neighborhood task force members that had attended felt their concerns were being dismissed. They reached out to Tier One for help, and Cosima Colvin did a huge amount of legwork to reach out to the other listed neighborhood representatives to find out what was going on. Some did not even know the task force existed.  

– It is unclear how the original task force members were selected or appointed.  It is also unclear how they were notified of the task force itself.  

The original task force member list posted on DSD’s website on May 24. You can see that the list currently posted on the DSD website has changed.

There seems to be a lack of transparency happening in DSD, and the updates to RM-4 and MF-33 will have a huge impact on all neighborhoods across the city. 

Cosima was able to reach Gloria Castillo for D8, and get a representative from D7 (Jorge dela Garza) added to the list of neighborhood task force members. With these additions, the neighborhood task force members were able to start coming up with some recommendations.   

Around the same time, I approached Councilman Treviño about a “Slot Home” ordinance that I had heard of in Denver, CO. The Councilman thought this would dovetail with the RM/MF Task Force and issued a memo that it should be incorporated.  This was discussed during the May 28th task force meeting, with the neighborhood showing specific examples of why and how they thought Denver’s ordinance could apply to San Antonio. Due to this memo, additional meetings were added to the task force schedule. 

Between the May 28th meeting and the June 25 meeting, community members discovered that in a previous version of the Unified Development Code, there was a restriction on the number of structures allowed on a lot. There is a math formula used to determine the number of units per acre (11), found on the Table in Section 35-310 of the UDC.  When applied to a 4000 SF lot, the maximum number of units allowed for RM-4 is one. However, since at least 2015 DSD has been allowing up to four units each in an individual structure on a RM-4 lot.

I attended the June 25th task force meeting.  The neighborhood representatives inquired about the previous version of the UDC regarding number of structures allowed on a lot. This and other concerns brought up at the meeting were dismissed by Cat Hernandez as typos in the UDC that were fixed in 2015. She did not offer any proof of the typos, or any other specifics. It seems many of the development standards that neighborhoods would support to protect character were removed from the UDC during the 2015 update. 

Additionally, during the June 25th meeting, Denver’s Slot Home ordinance was generally dismissed because “Denver has a form-based code,” despite the fact that San Antonio has several form based codes currently in use. 

615 Fulton Ave. in Alta Vista, Zoned RM-4

As the neighborhood task force members discussed some of their more specific concerns during the meeting, the task force members from the development community quickly started accusing the neighborhood members of making decisions for areas where they don’t live, specifically citing the west side and Denver Heights, which has a large concentration of RM-4 properties. A lot of time was spent discussing Denver Heights.  

Please note that the notes posted by DSD do not reflect my impression of the citizen comments made at the June 25, 2019 meeting.

After the meeting, I sent a request to DSD staff asking that Alan Neff from Denver Heights be added to the task force immediately. Cynthia Spielman reached out to them as well asking that Richard Garcia from Memorial Heights Neighborhood Association and member of the Westside Neighborhood Association Coalition also be added.  DSD refused to add either of them.  

At the July meeting there was a struggle to reach consensus on the many issues this task force is dealing with. Mike Shannon, the Director of Development Services, suggested they isses be tabled until the 2020 UDC review.

Two Tier One members in attendance at this meeting had their comments recorded by DSD:

  • Tami Kegley: Inappropriate zoning current exists and should be addressed. Perhaps look at a replat requirement when building a multifamily project, regardless if already platted.
  • Gemma Kennedy: A conceptual site design review should be required as this will save money in the long run.

Unfortunately these comments were not addressed or taken into account at the subsequent meetings, despite design review being one of the issues brought up n Councilman Treviño’s original CCR.

DSD’s August and September Task Force meeting notes can be viewed here:

Mary Johnson, President of Monte Vista Terrace Neighborhood Association and T1NC Steering Committee Member, has taken the lead in representing neighborhoods at the Task Force meetings. She has stated that there are still several items that don’t seem to be resolved, including heights, the number of individual structures allowed per lot, under-tuck parking, and orientation to the street.

Mary was not alone in this assessment. Cynthia Spielman, another Tier One Neighborhood Coaltion member that attended the September 24th meeting, commented that the developers were still pushing for eliminating the requirement for houses to face the street, and in showing examples of projects built without this orientation, seemed to prove to the community members the need for orientation to be explicitly spelled out in the code. 

Despite this continued lack of resolution, DSD has moved forward with issuing a draft of the proposed changes to the pertinent sections of code.

The CCR, notes from the previous meetings, and supporting documents can be viewed here: https://www.sanantonio.gov/DSD/Resources/Codes#233873531-rm-4–mf-33-ccr

How you can help:

There is an RM/MF Community Meeting being held Monday, October 14, 2019 at 6:00PM in the Board Room at 1901 S. Alamo. Please plan to attend this meeting.

DSD’s website states,

General Community Meeting(s) will also be held to gather more input from the public. Comments and recommendations made either through meetings or submitted through email will be posted here. Please be clear on each recommendation and its’ basis. Email comments to Kristie Flores, Planning Manager at kristie.flores@sanantonio.gov; her contact number is 210-207-5889.”

Please email kristie.flores@sanantonio.gov and copy your Council person, regarding the following items:

  1. RM and MF developments on lots less than one-third of an acre shall be one (1) structure with the appropriate number of units, (i.e. four (4) units in one dwelling on an RM-4 lot).
  2. Under-tuck parking shall not be allowed on RM and MF zoned properties under one-third of an acre. Parking shall be in the rear of the dwelling.
  3. All developments in RM and MF zoned properties on less than one-third of an acre shall be oriented so that the primary entrance of the structure (front door) shall face the street and shall have a visible porch, patio or canopy.
  4. The height of RM and MF zoned developments be limited to 35′ or 2.5 stories when measured to the top of the gable.
  5. On lots with more than one structure and less than 1 acre in size, a preliminary site plan shall be submitted for a preliminary site plan review with the COSA Building Department, and notification shall be sent to the registered neighborhood association and property owners within 200 feet of the property. The building permit number assigned at that time shall be used throughout the building process. 

Update (October 15, 2019):
The proposed changes will go to the PCTAC on October 21, followed by the Planning Commission on October 23. It will then head to the Zoning Commission in November, followed by the Planning and Community Development Committee and then finally City Council in December or January.

We encourage you to submit comments about the proposed changes in writing to Planning Manager, Kristie Flores and to copy your City Council representative on the email.

Updated to clarify the following terms: “unit,” “dwelling,” and “structure.”

Request from HWRA re Alazan Loft Project

By Cynthia Spielman and Tony Garcia

Update: August 22, 2019. City Council, after hours of testimony, approved the project without addressing the citizens except for Councilwoman Sandoval who applauded Councilwoman Gonzales’ efforts on the project and stated that she hoped that NRP/SAHA would work with the neighbors. Westside neighbors worked for weeks preparing and their efforts were not acknowledged.

Alazan Lofts Project
ZONING CASE Z-2019-1070005

Representatives from Historic Westside Residents Association (HWRA), Westside Neighborhood Association Coalition (WNAC), Tier One Neighborhood Coalition (T1NC), and the Esperanza Peace and Justice Center are concerned about the development of the Alazan Lofts, a partnership between San Antonio Housing Authority (SAHA) and NRP on lots on Colorado and Guadalupe. There is no opposition to the density nor to affordable housing which is always welcomed, but the neighborhood groups object strongly to the lack of effort to develop in a way that is compliant with the Guadalupe Westside Community Plan design guidelines, guidelines that were developed by community planners to protect its vulnerable neighborhood. There are major concerns about the lack of meaningful neighborhood input at the beginning of the project.  Of the seventeen meetings SAHA claims to have had with community, only three have been about this specific project. Only recently has SAHA and NRP worked with the community to find a solution.  The neighborhood groups would ideally like to see the community plan be adhered to with development at two stories, but are advocating for a compromise of three stories and have worked with the site plans to show how this is possible. It will be up to City Council to make this compromise binding. The Esperanza Peace and Justice Center, which is next door to the development, understands the efforts to compromise but supports the Guadalupe Westside Community Plan’s limits of two stories.   


Tier One Neighborhood Coalition neighborhoods and its suburban partners are concerned about this development setting a precedence of early project development without community input.  In order to make affordable housing a reality, it must have meaningful public input as well as comply with the neighborhood or community plan so that not only can we encourage affordable housing, but also preserve the communities that make up resilient neighborhoods.

The City Council hearing on this development will be Thursday, August 22ndat 2 p.m.
The issues of neighborhood engagement and respect for the community/neighborhood plan are important issues for all neighborhoods. Please come to show support if you can. 

 Read  Amelia Valdez’s Letter to Mayor Nirenberg regarding the Alazan 

Together we stand strong!

ZONING CASE Z-2019-10700050 (Council District 5): Ordinance amending the Zoning District Boundary from “MF-33 MLOD-2 MLR-2 AHOD” Multi-Family Lackland Military Lighting Overlay Military Lighting Region 2 Airport Hazard Overlay District to “IDZ-3 MLOD-2 MLR-2 AHOD” High Intensity Infill Development Zone Lackland Military Lighting Overlay Military Lighting Region 2 Airport Hazard Overlay District for multi-family uses not to exceed 90 total units and Non-Commercial Parking Lot on 0.355 acres out of NCB 2415, 0.680 acres out of NCB 2416, 0.191 acres out of NCB 2417, 1.226 acres out of NCB 2439, Lot 16, Lot 17, and Lot 18, Block 2, NCB 2440, located at 1013, 1014, 1015, 1018, 1019, 1021, 1022, 1023, 1101, 1102, 1107, 1114, 1121, 1201 El Paso Street, 210, 214, 316, 318, and 322 Torreon Street, and 803 South Colorado Street. Staff and Zoning Commission recommend Approval.

The Removing Barriers for Affordable Housing (RBAH) Task Force Notes and Information

The Removing Code Related Barriers for Affordable Housing Committee (RBAH)

What it is: This task force will look at the recommendations made by the Mayor’s Housing Task Force and will will focus on minimum lot size, building setbacks, street construction standards, utilities, storm water management, parks and open space requirements, and tree preservation among other recommendations and ideas. One of the important recommendations is how to build accessory dwelling units (ADUs) less expensively and more easily to help homeowners meet the rising costs of taxes, utilities, etc. and to provide affordable housing to seniors, students, and others. Read: A recent study, “Opportunity at Risk: San Antonio’s Older Affordable Housing Stock,” prepared for the San Antonio Office of Historic Preservation (OHP) by PlaceEconomics (2019) and

Note: Subcommittees have finished their recommendations and they will be reviewed by the entire task force on Friday, February 28th from 10 a.m. – noon. View the full recommendations here

T1NC Contact: Cynthia Spielman

CoSA Department: Neighborhood and Housing Services Department (NHSD) – Kristen Flores

Notes, minutes, recommendations are on RBAH page of NHSD

Subcommittee Meetings held at NHSD at 1400 S. Flores –

Focus Group Meetings TBA

Removing Barriers Updated 2020 Timeline and Meetings

EventDate & TimeLocation
Full Removing Barriers MeetingFriday, February 28th from 10 am – noon NHSD, Conference Room A 
Public Engagement Early MarchTBD
Final Removing Barriers MeetingTBA March NHSD, Conference Room A
Final Public EngagementEarly AprilTBD
Planning & Land Development Council CommitteeMonday, April 13thfrom 2 pm – 4 pm Municipal Plaza B Room
Housing CommissionWednesday, April 22ndfrom 4 pm – 6 pm TBD
Submit Amendments to Development Services April 30 by 4:30 pm Development Services

UDC Committees – What you need to know

Updated as needed.

Unified Development Codes (UDC) Changes Happening Now 

The UDC changes are happening now and it is important for neighborhoods to be involved. There are neighborhood leaders sitting on those committees, but we all need to be attending and supporting those leaders with input and help.
Several committees and technical working groups (TWG) are meeting now:

The Removing Code Related Barriers for Affordable Housing Committee (RBAH)

What it is: This committee will look at the recommendations made by the Mayor’s Housing Task Force and will will focus on minimum lot size, building setbacks, street construction standards, utilities, storm water management, parks and open space requirements, and tree preservation among other recommendations and idea

Why it is important: The kind of “by right” incentives for mixed-unit projects may be controversial. There is an effort to focus on non-profit affordable housing producers instead of giving more incentives to pro-profit developers for market rate housing. Read Rich Acosta’s (My City is My Home) remarks at the first meeting about the problems non-profit developers of affordable housing face.

Meetings: Meetings will be the second Monday of the month until December at 11:30 p.m. at One Stop (1901 S. Alamo) Board Room. RBAH meetings will be suspended while the subcommittees meet (see below).

Next Meeting: The task force has been divided into subcommittees: Accessory Dwelling Units (ADUs), Public Outreach, and Regulatory Cost Burdens. The regular task force will not meet for a while to give time for the committees to complete their work.

T1NC Contact: Cynthia Spielman

Other: Meeting minutes and information

CoSA Department: Neighborhood and Housing Services Department (NHSD) – Kristen Flores

Subcommittee Meetings held at NHSD at 1400 S. Flores

 Removing Barriers to Affordable Housing Public Engagement & Outreach 
• Wednesday, October 30th from 1:00 pm – 2:00 pm  • Wednesday, November 20th from 1:00 pm – 2:00 pm  • Wednesday, December 11th from 1:00 pm – 2:00 pm 
Accessory Dwelling Units 
• Friday, November 1st from 10 am – 11:30 am  • Friday, November 22nd from 10 am – 11:30 am  • Friday, December 13th from 10 am – 11:30 am 
Regulatory Cost Burden 
• Wednesday, November 6th from 2 pm – 3 pm  • Tuesday, November 26th from 2 pm – 3 pm  • Wednesday, December 18th from 2 pm – 3 pm 

The UDC Task Force – Historic/OHP/HDRC

What it is: The Historic UDC Task Force is working on UDC for historic districts and the process for designation. Read update from Monica Savino.

Why is important: This task force is not only important for historic districts: Design codes could be the model for any form-based codes that they City may consider in the future for compatible infill. Meetings will take place every two weeks from 3 – 5 p.m. on Thursdays from July 11 to September 12, 2019 at One Stop (1901 S. Alamo).

Next Meeting: This committee has adjourned. Its recommendations will presented in other committees and boards. Schedule TBA

T1NC Contact:  Tony Garcia or Monica Savino

CoSA Department: Office of Historic Preservation (OHP)

MF-33/RM-4 Committee

What it is: MF/RM Committee is working through issues about those lots zoned MF-33/RM-4 in our neighborhoods.  This committee is a result of a CCR by D1 Councilman Trevino. Read MF/RM Task Force Issues and MF/RM Task Force Update

They are also working on, at his request, Denver’s ordinance restricting or banning “slot homes” condos or apartments crowded into a lot that face one another which have been the model for developers in the downtown neighborhoods. There has been an effort to include a representative from the Westside and Denver Heights because they will be directly affected but DSD has denied the requests for inclusion.

Why it is important: Cosima Colvin explains how important this issue is on Tier One Neighborhood Coalition Face Book page:   “Several of the T1NC Neighborhoods are on the Task Force and have worked with other T1NC members on an ad hoc committee to develop language that will address the concerns that many of our neighborhoods have regarding these two zoning categories and how to balance developers’ “by right” development choices with neighborhood preservation. We strongly urge neighborhoods to check DSD’s Zoning Map webpage to see where you may have RM4 and/or MF33 Zoning in your neighborhoods and understand what those zoning districts/categories will allow. More info is available here: https://www.sanantonio.gov/DSD/Resources/Codes#233873531-rm-4–mf-33-ccr

So far neighborhood representatives are facing stiff opposition from the development community on the committee and need support. See Mary Johnson’s (Committee member and President of Monte Vista Terrace) interview here .

Next Meeting: This committee has adjourned. Recommendations will be reviewed by PCTAC on Monday, October 21st at 9 a.m. at Board Room at Development Services, 1901 S Alamo St.

T1NC Contact: Mary Johnson

CoSA Department: Development Services Department (DSD) – Catherine Hernandez