Throughout the project, we’ll post questions and comments that have been submitted on comment cards collected at community meetings, sent via email or submitted via the website.

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Adus And Owner Occupancy

I would like to see the matter of an owner-occupancy requirement for ADUs given more discussion, at the very least for EN, RN-1, and RN-2 neighborhoods. Previously we have been told that this is not enforceable, but many other cities do enforce this requirement or at least have it on the books. Not doing so opens up our neighborhoods to opportunistic developers who may or may not care about the impact they have on neighbors. Citizens who chose to make the biggest investment of their lives in the city did not expect their beautiful "single family dwelling" neighborhoods to be potentially doubled (or more) in density by a mere stroke of the pen. In my opinion, this issue alone should be put to a referendum, but I understand this is highly unlikely. I make this appeal here to ask that you please give further thought to allowing the taxpayers a little more control in protecting their investment in this city, both monetary and sentimental.

Thank you.
Staff Reply:

Proposed Residential Zoning Changes

I am writing as a long-time resident of the West Hills Community. I have lived in West Hills for more than 50 years. I value the historical and cultural significance of our community and am hoping you will take steps to preserve our zoning.

Please don't allow my neighbors to build structures for alternative housing in their back yards.

Please don't allow my neighbors to park their motor homes in their driveways.

Please don't open us up to greater housing density.

West Hills is an important part of the West Knoxville community. We need your help in preserving the continuity of our well-kept neighborhood with its large spacious lots, mature trees and play areas.

Thanks for your help!
Staff Reply:

Lot Size Distribution (by Width)

In the presentation used at the City Council worksop, the distribution of residential lot sizes by square footage shows that most lots are conforming based on minimum area. Although this is great, it does not tell the entire story of how many lots will be non-conforming. Can you please put together a distribution of lot sizes by width? There are many lots in the inner city that are smaller than the minimum 50' width.

Many homes in Beaumont, Mechanicsville, Lonsdale have small lot sizes, and homes that use a very large percentage of the lot width. With the required side setbacks in the draft, we are setting ourselves up to build skinny homes that do not fit the neighborhood, and also result in less incentive to build on smaller lots because.

I suggest something that looks at, for currently existing lots, allowing minimum side setbacks of the primary structure in residential areas, to take into account the average of the blackface. Or make setbacks a % of the lot if the width is within 35-50'. Something that will reduce the number of nonconforming lots when taking into account width. These type of lots are in some of the poorest of our neighborhoods and we can't afford to create disincentive to invest in new structures. Not everyone will have the time/money to jump through hoops of BZA to get setbacks waived on small lots.
Staff Reply:


Will we be able to have our 16 foot camper parked in our driveway? Also, is the land in front of our house going to be developed, it's full of sink holes. One final question, is Rohar Road going to be extended, right now it's a dead end. We like the way our street is now. Thank you for reading my comments.
Staff Reply:
Thanks for your interest in Recode and for your questions. You will still be able to park your camper in your driveway but you may have to screen it with landscaping from the street. The development of the land in front of your house is dependent upon the desires of the property owner. If the owner did desire decide to pursue development of the property, all applicable standards would have to be met. The zoning ordinance does not dictate nor does it propose street extensions. The City Engineering Department may know if there are plans to extend the street.

Public Comments From Business Owner


I recently attended a meeting and am following up with some comments. My family and I work, live, worship, and attend school in the vicinity of the Magnolia corridor. I have a few suggestions below based on our experience of living life, operating a business, and owning commercial property in the area.

I greatly appreciate your consideration of "industrial craft" designations. We looked for a year before finding an affordable building for our business size. In two months we have already added two full time positions and plan to add more within the year. We would be classified as industrial craft and would have been unable to afford (and didn't need) anything in an industrial park. At the same time, our business is in high demand. There are construction projects in Knoxville that cannot find highly skilled workers to meet their demand. Not considering the needs for skilled trade businesses and workers, would be detrimental to Knoxville's economy. The final document should consider how the zoning code affects businesses employing highly skilled workers (especially those with 1-10 employees).

I would like to see lot coverage in the downtown neighborhoods increased from 30% to approximately 50%. I believe many existing single family parcels and the historical development pattern more closely resemble a 50% lot coverage. I know a number of people who have been prevented from building accessory structures such as sheds because of the 30% limitation. However, their neighbors have the original shed or carriage house and in combination with their principal structure, the lot coverage is at least 50% if not more.

I support allowing accessory dwelling units. The infrastructure for high density is already in place and it should be taken advantage of. I believe parking concerns can be mitigated through limitations. On my street, we have several houses that have only one or two cars with two dwelling units on the lot. We also have a SF house with 7 cars (it has been this way for 10 years). This is an enforcement issue.

Lastly, I wonder how the new zoning regulations will affect schools. Funding for urban schools should not be decreased due to "publicly funded sprawl." I hope that this zoning code does not overextend schools that are already at capacity and not supporting schools that are under capacity. I know this is a large, complicated, multifaceted issue, but still it's one to consider.

I appreciate the time and effort placed in this process and look forward to the final product in a timely manner.
Staff Reply:

Apartments And Infrastructure

When new apartment complexes, subdivisions, or other large projects are considered, PLEASE take into account the existing infrastructure. I live off of Bluerass Road in west Knoxville. In the past couple of years, we have had a large subdivision put in on Mourfield Rd, which caused damage to that road (small, 2 lane, no shoulder, windy, and steep), and caused us to go from only having power outages in weather situations to having weekly and occasionally daily power outages while they were building that subdivision. Now there is an apartment complex going in on Emory Church Road that is causing even more issues. We have frequent power outages during construction. Emory Church Road is not a large enough road to accommodate the traffic. The road has almost been destroyed by the construction equipment, and they are in the process of adding a traffic light because of the increase in traffic. That traffic light project has been TERRIBLE. My child attends preschool at West Emory Presbyterian Church, at the corner of Emory Church Road and Westland Dr. The project took over 2 months, rules were not followed, the parking lot was destroyed and partially blocked for nearly a month, and the workers were just plain rude. The light still isn't up, but the turn lane on Westland has been re-painted to accommodate when the light is in effect, making it very difficult to turn left onto Westland.

All this to say....the infrastructure should have been addressed BEFORE any of these projects were approved and started. The LCUB substation on Westland Dr. needs to be larger to accommodate the new buildings so that existing customers didn't have to experience 2 years of frequent power outages. The roads should have been widened and supported before construction equipment destroyed them. The light should have been installed before construction on the building projects began.
Staff Reply:

Section 10.3 & 10.4 - Accessory Structures And Uses

I believe that there should be more consistency between section 10.3 (F) CARPORTS and section 10.3 (N) GARAGE, DETACHED.

First, does section 10.3 (F) apply to detached carports only, or attached and detached carports? Clarification there would be beneficial.

Second, why must a carport be set back from side lot lines 10 feet whereas a detached garage requires no setback from side lot lines? I would think application of setbacks for these structures would be consistent with each other.

It may be that each could be addressed in a consistent manner with regard to Table 10-1, Permitted Encroachments as unenclosed porches (similar to a carport) and sheds (similar to a detached garage).

Staff Reply:

Streetscape Section In The Sw District

The entire streetscapes section has been deleted, with a note that it "should" be moved to the subdivision ROW standards. What if any plans have been made to do this? I acknowledge that this section has problems, but a better solution would be to leave it in Recode and then come back and rework it as needed rather than to just delete it with a vague promise that it will go elsewhere.
Staff Reply:
The streetscape standards section of the SW District has been deleted from the zoning. It addressed things like ROW width, movement type, design speed, pedestrian crossing time, curb radius, etc. These are things that ultimately don't belong in the zoning code, and should be incorporated into the subdivision ordinance. More specifically, the recommendation is that they should be moved to the streets and right-of-way standards in the subdivision, where these types of elements are already being addressed (Section 3.04 of the City/County Subdivision Ordinance, for reference).

The subdivision ordinance would need to be amended to include these standards.

Recode Knoxville "bring Back The Orange!"

Bring back the orange in our core neighborhoods by utilizing RN-3,4, and 5 zones to allow for a greater range of housing choices in walkable, bus-friendly neighborhoods. Please adopt appropriate zoning & standards to encourage good design, scale, and development in a manner that will protect our neighborhoods while still allowing them to evolve.
Staff Reply:

Recode's Impact On South Waterfront Form-based Code

I am writing you with dismay about how the current 2nd round draft of Recode Knoxville handles the long studied, community-based, community-requested South Waterfront Form-based Code. I participated in the public discussions and feedback as part of the Round 1 of Recode Knoxville. At that time I was told explicitly in a public meeting in regards to a question about the current, existing form-based codes used in Knoxville that there wouldn't be major changes to current form-based codes used in Knoxville, only clean-up on the edges where ideas hadn't solidly been hammered out in the code.

The current 2nd round draft of Recode Knoxville does not appear to hold to the statement made at that meeting. I'm concerned to see major changes being proposed, including some that go against the very intent of what the SW code was set-up to accomplish.

Form-based code districts should be dealt with individually if any changes are made. That's the very nature of form-based districts. They're customized, specialized and unique. The form-based code for each district is meant to "fit like a glove" to address the particular development opportunities for that district, and has to be handled accordingly at every step. That clearly includes revisions. A board, sweeping update to the entire Code, such as Recode Knoxville, is not the appropriate place to dig into the guts, the thrust of the South Waterfront Form-based Code and muck around.

The South Waterfront Form-based Vision Plan and Code included months of work and community involved meetings. The community was engaged in the process and had embraced the adoption of the code at it's completion. The public was endorsing an urban, pedestrian-friendly connected community that provided public access to the river. Below are a few examples of how the 2nd Round of Recode Knoxville glosses over these facts and preverts the intention of the South Waterfront Form-based Code:

The prohibited-use section has been deleted. We need to keep the few prohibitions listed in this section, such as heavy industrial. This is critical to a successfully grown community where people want to live and engage.

  • The prohibition on gated communities has been deleted. Gated communities go against the intent of the South Waterfront Form-based Code's goals of an urban, pedestrian friendly, community with a sense of place. Gated communities negatively impact connectivity, and can diminish access to the river. This prohibition was strongly supported by the South Knoxville community and needs to remain in the code.

  • The off-street parking section has been deleted and replaced with a reference to the general parking section in the Recode document. Unless that section includes a prohibition on parking lots in the front, which I doubt, this prohibition needs to remain in the code. Front parking lots are not part of an urban, pedestrian-friendly community. Also, the original code has different parking max/mins for each of the seven SW districts. Deleting all the parking-related code deletes the different parking max/mins for each of the seven South Waterfront districts. We need those in the South Waterfront code because parking min/max requirements can't be determined by use in a form-based code.

  • The provision setting the maximum block size perimeter has been deleted. This provision was included to prevent superblocks, which are not what the South Waterfront code intended to build an urban, pedestrian-friendly community. Superblocks have a negative impact on connectivity, and can diminish access to the river. This provison needs to stay in the code.

  • The 70 foot river buffer has been deleted. This was strongly supported by the community and well-vetted before the code was adopted and needs to remain.

  • The entire streetscapes section has been deleted. If we are treating the South Waterfront streetscapes like all other streetscapes in Knoxville, then the South Waterfront will lose it's opportunity to be a unique district with it's own pull and character to help strengthen and diversify Knoxville. This section need to remain.

Thank you.
Staff Reply:

Recode Knoxville

I have a concern which was identified in the first draft of the RECODE Knoxville that could impact West Hills. The concern is regarding the changing of the zone for the area on Middlebrook where Tennova was to build. The recode Knoxville seems to be a backhanded way to change allowed land usages without input from impacted neighborhoods. Several other concerns with the recode draft include:

- Less restrictive Accessary dwelling unit (ADU) requirement in residential neighborhoods.
- Zoning changes without specific notice of changes.
- Expanded allowable land uses in certain zones.
- Increased administrative challenges for impacted citizens and neighborhoods to challenge proposed changes to allowed land use.
- A rush to obtain city council approval of the recode to meet an arbitrary project schedule at the sacrifice of resolution of identified issues.

I am opposed to the changing of the Zoning of the hospital property from “Office" to "Office Park” for the reasons identified above.
Staff Reply:


How will the recoding affect taxes? Will they go up, even if we choose not to construct an ADU on our property? Will our current infrastructure be able to handle the increased usage of ADUs in residential neighborhoods? How will this affect property values in neighborhoods? What kind of standards will these ADUs be held to? There are quite a few questions that this website doesn't answer
Staff Reply:

Comments On South Waterfront Portion Of Recode, Version 2

First, thank you all for all the hard work on Recode. Knoxville has needed this for quite a while and I'm delighted to see it finally moving forward.

I'm a resident of south Knoxville and a former member of the South Waterfront Advisory Committee who was very involved in the creation of the South Waterfront Vision Plan and Code. For weeks, I've had various people tell me that Recode wasn't going to make major changes to the SW code, so I've really not paid much attention to that section of the proposed new code. However, after reviewing Recode version 2, I'm very concerned to see that there are indeed major changes being proposed including some that violate the entire spirit of what the SW code was intended to accomplish.

The creation of the Vision Plan and code included months of work and more meetings than I can count. The community was very engaged in this process. A lot of south Knoxvillians were originally wary of the entire endeavor but by the end of the process had embraced the adoption of the code. They were endorsing an urban (rather than suburban), pedestrian-friendly (rather than car-centric) connected community that provided maximum public access to the river. Most of my concerns about changes relate to these goals.

  • The entire first section on prohibited uses has been deleted. Granted, we wanted a form-based rather than a use-base code, with maximum mixed usage. But we need to keep the few prohibitions listed in this section, such as heavy industrial.

  • The prohibition on gated communities has been deleted. Gated communities are not urban, they are not pedestrian friendly, they don't create a sense of community, they negatively impact connectivity, and depending on where they are located they may diminish access to the river. This prohibition was strongly supported by the south Knoxville community and needs to remain in the code.

  • The entire section on off-street parking has been deleted and replaced with a reference to the general parking section in the Recode document. Unless that section includes a prohibition on parking lots in the front, which I doubt, this prohibition needs to remain in the code. Front parking lots are not urban and they are not pedestrian-friendly. Also, the original code has different parking max/mins for each of the seven SW districts. Deleting all the parking-related code presumably deletes these differing standards as well. We need those in the SW code because since it's form-based, parking min/max requirements can't be determined by use.

  • The provision setting the maximum block size perimeter at 1400 feet has been deleted. This provision was included to prevent superblocks, which are absolutely not what the Vision Plan envisions. Again, superblocks are not urban, they're not pedestrian friendly, they have a negative impact on connectivity, and depending on their location could diminish access to the river. This provison needs to stay in the code.

  • The 70 foot river buffer (measured from the riverbank) has been deleted. This was thoroughly debated before the code was adopted and needs to remain.

  • The entire streetscapes section has been deleted, with a note that it should be moved to the subdivision ROW standards. What if any plans have been made to do this? I acknowledge that this section has problems, but a better solution would be to leave it in Recode and then come back and rework it as needed rather than to just delete it with a vague promise that it will go elsewhere.

  • The SW5 and SW7 front setbacks have been changed. I personally am okay with this change but it's one the community should be aware of.

  • The entire signage section has been deleted. Perhaps most of this is covered adequately in the new sign ordinance which was adopted after the SW code. But again, the community should be aware of this and there should be a point by point comparison to make sure that nothing crucial has been deleted

Finally, I plan to share my comments with my south Knoxville neighbors who may not be aware of what's proposed. I also strongly suggest that a meeting in south Knoxville should be scheduled to go over all the proposed changes to the SW code since these are indeed major changes.

Thanks for the opportunity to comment.
Staff Reply:

Bring Back The Orange!

Bring back the orange in our core neighborhoods by utilizing RN-3,4, and 5 zones to allow for a greater range of housing choices in walkable, bus-friendly neighborhoods. Please adopt appropriate zoning & standards to encourage good design, scale, and development in a manner that will protect our neighborhoods while still allowing them to evolve.
Staff Reply:

Recode Knoxville -- Op Zoning Districts 10-8-18


I am a resident of West Hills and frequently travel on Middlebrook Pike, Weisgarber, and Lonas.

In looking at Draft 1 of the proposed Maps for Middlebrook Pike, Weisgarber, and Lonas areas, I noticed that there are many parcels with a proposed OP (Office Park) zoning district. This includes the large parcel of vacant land which Tennova had planned to build a hospital, vacant parcels across Middlebrook Pike, and other nearby parcels that are either vacant land or have already been developed as offices.

The Recode Use Matrix, Article 9.2 shows the Permitted Uses for the OP zoning district. OP includes Eating and Drinking Establishments, Retail Goods Establishments, and Food Truck Parks, among other things as Permitted Uses. Gas Stations are allowed as a Special Use. These uses are very different from what is presently allowed in Office zoning districts in our existing Ordinance.

These types of developments would increase traffic considerably, and add additional noise and bright lights which will adversely affect West Hills properties which are adjacent to or nearby the Tennova property, and will adversely affect many West HIlls residents and others who use the already heavily traveled Middlebrook Pike/Weisgarber corridors.

Office zoned properties have long been used as a buffer between residential and commercial properties and that should be maintained for these type properties under Recode.

Therefore, I request that Eating and Drinking Establishments, Retail Goods Sales, Food Truck Parks and Gas Stations be removed as Permitted Uses or Special Uses in the Office Park zoning districts. In addition, Eating and Drinking Establishments should be allowed only as Accessory Uses to serve the employees and clients of that office building, along with standards that the restaurant not be a free-standing building. It should only be accessible from within the building.

Thank you for your consideration.
Staff Reply:

Bring Back The Orange !

Bring Back the Orange Zones in our core neighborhoods, particularly close to the KAT bus lines, by utilizing RN-3,4, and 5 zones to allow for a greater range of housing choices in walkable, bus-friendly neighborhoods. Please adopt appropriate zoning & standards that will encourage good design, scale, and development in a manner that will protect our neighborhoods while still allowing them to evolve.
Staff Reply:


Please don't rezone Parkridge. I am a victim of domestic abuse. I need affordable housing that is not in the unsafe housing projects.
Staff Reply:

Add More Orange To The Map!

We need more affordable housing options around downtown and creative thinking to make more healthy density a reality. Sustainable households are more important than boom and bust cycle property appreciation schemes.
Staff Reply:

We Need More Options For Affordable Housing!

Bring Back the Orange! in our core neighborhoods by utilizing RN-3,4, and 5 zones to allow for a greater range of housing choices in walkable, bus-friendly neighborhoods. Please adopt appropriate zoning & standards to encourage good design, scale, and development in a manner that will protect our neighborhoods while still allowing them to evolve.
Staff Reply:

Bring Back The Orange!

Bring Back the Orange! Our City NEEDS this and I know it can be done with good design and scale of development.
Staff Reply:

Increasing Housing Density

I want to see far more density in this zoning Recode. We need far more housing, especially within the 4 mile radius of downtown. Increasing building heights, and adding ADU's in existing neighborhoods is vital in order to achieve this. Moving to single family only perpetuates segregation within our city.

Thank for your efforts, but we.need. more. Housing options!
Staff Reply:

More Housing Choices For Knoxville

Bring Back the Orange! in our core neighborhoods by utilizing RN-3,4, and 5 zones to allow for a greater range of housing choices in walkable, bus-friendly neighborhoods. Please adopt appropriate zoning & standards to encourage good design, scale, and development in a manner that will protect our neighborhoods while still allowing them to evolve.
Staff Reply:


Affordable housing is at crisis point for many people in Knoxville. Homelessness is on the rise in our city due to a lack of affordable housing.

"Bring Back the Orange! in our core neighborhoods by utilizing RN-3,4, and 5 zones to allow for a greater range of housing choices in walkable, bus-friendly neighborhoods. Please adopt appropriate zoning & standards to encourage good design, scale, and development in a manner that will protect our neighborhoods while still allowing them to evolve."
Staff Reply:

Article 5.1.a Office Zoning District Purpose Statement

There appears to be no accommodation for in patient services related to behavioral health/temporary incarceration in the definition of the Office District. Yet, the area that includes the properties owned and operated by Helen Ross McNabb at 3343 Dewine Road appears to continue to be defined as Office. Is it reasonable to assume that these activities will not be considered appropriate in Office districts in the future. If so, what District will they be permitted in?
Staff Reply:
This property is being proposed as Institutional on the second map which will be available for review mid week.

Article 4.1 Purpose Statements

At the end of every Residential Neighborhood Purpose Statement is the sentence: Limited nonresidential uses that are compatible with the character of the district may also be permitted. I can not find anywhere in this draft where the elements that make up the "character" of the district are defined nor the weight that would be applied to each of those elements when/if a permit for a nonresidential use is applied for. Such a broad statement with no definition is exactly what citizens fear and have been accustomed to as uses that do not appear to be compatible encroach into residential and non-residential zoning districts alike. Character, like beauty, is in the eye of the beholder. If you are unable to define it, you are not afforded the luxury of making up the rules as you go along!
Staff Reply:
Thank you for taking the time to review the draft ordinance! The character of each district is defined in multiple ways within the ordinance:

  • The purpose statement for each district, which identifies the intent of the regulations, and outlines a general character for each of the districts through descriptive language like “exhibiting a predominant
    development pattern of single-family homes on relatively large lots and with generous setbacks,”(RN-1) or “comprising a heterogeneous mix of single-family, two-family, townhouse, and multi-family dwellings.” (RN-5)

  • The dimensional standards for each district, which establish the physical parameters for development in the districts, and as such are probably the most explicit means of defining the character of each district.

  • Design standards (where applicable), for the EN district, or for pocket neighborhoods in the RN-4 add further detail to the character of those districts.

  • Site Development Standards, Use Standards, Landscape, etc. All work together to further define character â€" through lighting standards that vary based on location and district, to accessory structure regulations that acknowledge the physical size of lots, use standards with varying applicability by district and lot size, etc.

Finally, when we’re talking about nonresidential uses that are compatible with the character of these districts, the things permitted as compatible are uses like parks, community centers, daycare homes, etc. If there’s anything that potentially has greater impacts, they have been made special uses, which would necessitate review to ensure that they meet the approval standards for a special use. The allowable uses for each district can be found in this section.

If you have any further questions or comments please let us know.

Bring Back the Orange
Staff Reply:

Bring Back R3 And R4


I recently was reviewing the prosed recode map and I have some great concern over the removal of the orange on the map. Duplexes and multifamily complexes create affordable housing and without them, it will greatly hurt our city. Fixed supply with growing demand will increase property values to the point where they are no longer affordable. This will hurt 2 groups in particular. Those new to the work force graduating college and the creative class. College students graduate from UT every semester and consider staying in our city and calling it home. The city is trying to attract new businesses to our town. It creates jobs, brings in new tax dollars and helps all in our city thrive. Without affordable housing for the new work force, many will consider a new city to move to and without that work force, businesses will find our city less attractive to call home. Our amazing creative class also needs a place to call home. We have embraced the maker's city branding and would like to create a space for creatives and makers. They need affordable housing close to their businesses downtown and R3 and R4 do that. Please consider bringing back the orange to the map.
Staff Reply:

Recode Comments From The Knoxville Area Association Of Realtors

City Council Members:

Please find attached materials outlining feedback from our association and our residential and commercial Realtor members.

1. ADU memo - MLS stats and research on other municipality's ADU ordinances and experiences

2. Missing Middle Housing - a global issue in Recode residential zones where current R-2 zones have been downzoned to proposed RN-2. Current R-2 should be rezoned to proposed RN-5, as stated in the Recode Residential Comparison Chart, to keep existing uses available in those areas. Also, the Recode map needs to be looked at critically across all residential zones in Knoxville to return these middle-housing opportunities to those areas (A local example included in the handout is the Magnolia corridor where current R-2 was downzoned to RN-2.).

3. Keep Knoxville Affordable - a handout I received from Matt Sterling, with input from other groups who are concerned about downzoning and lack of affordable housing (not govt subsidized housing, but rather, housing a larger segment of our population can afford). Population projections suggest that the larger Knoxville/Knox County area will need to add (conservatively) upwards of 3-5 housing units per day to meet these growth needs.

4. Residential Top Issues - compares the proposed RN districts and asks the question why do we have 7 residential districts? (this is not meant to be a comprehensive list but some of the most important issues)

5. Commercial & Industrial Top Issues - a bullet point list of key issues found in commercial, industrial, and other non-residential zones (this is not meant to be a comprehensive list, but a list of the most important issues we've collected from the active Realtor and developer community). Also, the Use Matrix in Section 9.2 should be looked at more closely to ensure we are not creating a greater number of nonconforming uses in these zones. Many comments I have received concern not where Recode Permits or allows Special Use, but where it does not allow either of these. Look at the blanks, where there is not a "P" or "S" use listed, ask why that box is blank and should it be filled; what problems are we creating by leaving out "P" and "S" uses in various zones? The design standards in Recode are protective enough that areas around commercial development will be protected, the building and lot will function well and have an acceptable appearance no matter the use inside the structure, to a large extent.

Recode is quite an undertaking and I appreciate your tireless work on this project. Sorry for sending this so close to the workshop time; informational gathering for Recode has been a tremendous effort as I know you are aware. I am happy to address any concerns and questions you may have. Please feel free to contact me anytime.


Jennifer Roche, JD, RCE
Governmental Affairs Director
Knoxville Area Association of Realtors
609 Weisgarber Road, Knoxville, TN 37919
Staff Reply:

The Lack Of Duplexes

In response to the general consensus circulating... "If duplexes aren't being built, the market doesn't want/need them, so why are we trying to allow more of them?"

For R1: Duplex allowed on Review w/ lot size minimum of 15,000 sq.ft.

Most R1 neighborhoods are typically auto-oriented (non transit friendly) & suburban with larger homes on larger lots. The need for duplexes in those areas is low and naturally their occurrence is low. The assumption that the market signals are influencing the development of duplexes is likely true in most suburban R-1 zones.

On the contrary, Oakwood, a walkable & transit-friendly neighborhood, is a mixture of R1 (IH-1) & R2. Lot sizes range from < 5000 sq.ft. to 7500+ sq.ft. A new duplex would require multiple lots, therefore they aren't done. There are however, many older duplexes that exist currently as represented by the"checker-board" of R1/R2 on the current zoning map. Building new would require up-zoning, special approval, and variances... therefore they aren't being built.

For Oakwood, the market's need & desire has no way to respond because a duplex is, by-default, prohibited.
[Moving forward RN-3 more appropriately represents the development pattern of Oakwood, and would allow more by right development & less special use approval for duplexes.]

- - -

R1-A: Duplex permitted by right w/ lot size minimum of 10,000 sq.ft.

This district is well represented in our central-city neighborhoods. It is specified as"low to medium density" but"nearly 70% of lots [Zoned R1-A] do not meet the required 7,500 sq.ft. minimum lot area." (pg. 12 ReCode Technical Review Report) So although a duplex IS permitted on paper, it is prohibited in practice... as we see with Old North. Old North is another walkable & transit friendly neighborhood, with the the majority of lots being under the 10,000 sq.ft. required for a duplex. Again, the market's need & desire is unable to respond because a duplex is, by-default, prohibited.

An abundance of multi-family structures at various scales exist currently in most of our R1-A transit friendly neighborhoods. These areas need a closer look and a smaller paintbrush to more appropriately zone them to reflect the development patterns that currently exist within them. We must ensure that our central-city neighborhoods are not a static ecosystem, but rather a dynamic one. We must ensure they're able to evolve over time, not radically, but incrementally.. to ensure they're meeting the needs of those who are currently there as well as those who will be there in the future.

- - -

R-2: Req'd lot size is 7500 sq.ft. for the first dwelling + 1500 sq.ft for each additional dwelling. Therefore a duplex would require 9000 sq.ft.

This district is "medium-density" yet still not conducive for a duplex. "50% of the lot sizes within the R-2 district do NOT meet the required 7500 sq.ft. minimum lot standard." (pg. 12 - ReCode Technical Review Report) so very rarely would we see 9000 sq.ft. available for duplex construction. Again, duplexes aren't (and cannot be) built without special circumstance or multiple lot aquisitions, at which point it's more favorable to build two single family homes.

A duplex is Small-Scale Development 101... an incremental step towards meeting the demand for housing within our transit-friendly neighborhoods. They're as easy to build & finance as a single family home (from a codes & lending standpoint). A duplex even provides opportunity & incentive for owner-occupancy, empowering more folks to invest & live in the neighborhoods they love. A duplex easily blends in with it's surroundings and provides housing opportunities at a scale that currently isn't available (and hasn't been allowed) within our transit friendly neighborhoods.

The lack of recent Duplex construction/conversion is not based on market trends, citizen desires, or lack of profitability. This deficiency is directly tied to our present Zoning & Lot size requirements. To move Knoxville in a positive direction, it's imperative that we allow this age old tool of incremental development to be used once again within our transit friendly neighborhoods.

...and do so without a 2 space per unit parking minimum!

Thank you for the consideration,
Staff Reply:

Application Of Rn-3 + Rn-4

As noted on page 13 in the Technical Review Report,

The purpose of the RN-2 District is to, "accommodate development of single family homes on mid-size lots, with specific standards for duplexes as special use."

The purpose of the RN-3 District is to, "accommodate single & two family residential development on smaller lots; multi-family permitted as special use."

- - -

In Draft 2, the minimum lot size for RN-2 was reduced to 5000 sq.ft. (respectively, a small lot size) to reduce the amount of non-conformities.

Rather than more accurately representing many of our existing R-2 neighborhoods with RN-3, these neighborhoods were down-zoned and a special reduction in lot size was made to "make them conform" to a zoning designation that does not well represent what we see on the ground (a mix of single + two family dwellings as well as small-scale multi-family permitted as special use).

A better reflection of the true development pattern & lot size of many of our current R-2 neighborhoods would be the application of RN-3.

As written, this creates more instances requiring special use approval and limits by right development, both which are in direct opposition to "help facilitate more by-right development [and] reduce reliance on special approvals." (Technical Report Pg. 11)
Staff Reply:

Recoding Residential Areas

Question-Why are some areas within the same are are coded R! and others are coded R2. My property is located on Michaels Ln and is coded as R1. What is the difference between R1 and R2 coding codes?
Staff Reply:

Lighting Standards - Lumens At Lot Line?

10.2 - Exterior Lighting only specifies that fixtures must be a 75 degree cut-off luminaire and shield the light source from an observer 3.5 ft above the ground along an abutting lot line.

This doesn't regulate the intensity (lumens or footcandle) of the light that comes across lot line. Intense lighting (say a couple of candlepower) would cross the lot line at a 15 degree down angle and then reflect off the ground surface. Even grass reflects that light some, but other surfaces such as a light concrete would significantly reflect the light up. This would put the burden on the adjacent lot owner to install non-reflective surfaces within the 13.5' area next to the lot line that a light source crossing 3.5' above the ground at the lot line would reach.

By neglecting to specify a light intensity that crosses the lot line, another issue is caused. There is nothing that prohibits a brightly lit interior light source of a building from emitting light out and not being considered a luminaire. There's also nothing that prohibits a bright wall (say the lightly colored metal wall of a Dollar General store) to have a wall-pack light installed on it that reflects off the wall and causes a great deal of light trespass to adjacent lots.

The ordinance should specify light trespass standards for all districts, not just SW districts.

There needs to be a definition for "luminaire" in the definitions section as well, to ensure that it includes all exterior lighting, and not just luminaires mounted on poles. Example: wall mounted lighting, floodlights, etc. should be explicitly included in the definition.
Staff Reply:

Put Back The Orange

Here in the fall season with the Vols trying to get into the spirit for winning games, the Metropolitan Planning Commision is taking away the color orange from the community. One of the major problems in Knoxville - in Knox County - and in all communities across the country affordable housing is the major need for all cities and counties. By limiting so drastically the areas where multiple housing buildings can be be built, the Commission is building into the local community more homeless families and more families less able to afford the bare necessities for their families.

Pleas think twice - then three times - then delay for a month and think again about how your decisions may affect the people living in Knoxville. Do you really want to make decent housing unavailable for more families in Knoxville and Knox County in the years to come. I hope that is not your desire.

Staff Reply:


I am concerned that the new map has less affordable housing when more is needed. Please reconsider and add the orange areas back.
Staff Reply:

Broadway Corridor Task Force - General Comments

The Broadway Corridor Task Force respectfully submits our general comments/requests regarding the Zoning Code below. We have compiled a formal document (which may be more legible with diagrams and text formatting) that also include our parcel and/or "area specific" comments which have been submitted/requested within the Draft 1 map over the past few weeks. We will send this complete document via email this evening (September 20th), once complete.

Thank you, James Ryan & Kyle Anne Lang, BCTF Co-Chairs


We support:
- The allowance of mixed-use (residential over commercial/office) along the Broadway Corridor.
- Build-To-Zones along Broadway in order to encourage a more 'urban edge' along the corridor, as well as force parking to be located at the side, or more preferably the rear of buildings.
- Current landscape buffering requirements between commercial and residential properties.
- Commercial Design Standards (especially in relation to the Broadway Corridor)
- CN designation for properties along E Woodland, across from Physician's Regional Medical Center. (904 E Woodland; 1034 E Woodland)
- CN designation used as a buffer between high density (and/or DK zoning) and single family residences, as well as appropriate pockets along a commercial corridor.
- Reduced parking requirements for pedestrian-oriented zones (however request additional reductions, see below)


Parking Requirements related to Transit and/or Transit Oriented Development

In addition to current parking requirement reductions as associated with C-N and certain C-G zones, we would ask MPC and Recode to consider a parking reduction for developments within a certain distance to a public transportation stop/center (IE the Broadway Shopping Center) to encourage more Transit-Oriented and Mixed-Use Development.?

Office Space Inconsistent Setbacks, Change to C-G-2

Office zoning along Broadway (and other urban corridors) should have minimum front, side, and rear setbacks that match adjacent Commercial parcels. C-N, and C-G-1, 2 and 3 all allow no minimum front setback or 0' - which would create strange conditions along corridor where one parcel may be Commercial and an adjacent one Office. This would not allow for a consistent 'urban edge' along the street, where one building may have a 0' setback, and then the adjacent building is required to step back 15' just because it is Office zoning.

In looking further into the differences between Office and C-G-2 zoning, we see no reason why Office zoning is necessary along Broadway, and even noticed some non-compliance with proposed Office Zoning (for example, Independent Living facilities zoned Office that does not allow this use). Therefore, we request all currently proposed Office zoning along Broadway be zoned as C-G-2. In general, the BCTF questions whether an Office zone is a redundant zone to the new OP zone, since Offices are a compliant use within the C-G zones.

If for some reason this change is not possible, we suggest an Office Zone subsidiary for urban corridors (such as O-2 or O-Urban) that has no minimum front setback, to allow for office zoning adjacent to C-N or C-G parcels to have the same setback, as well as allow no minimum interior side setback to allow for zero-lot lines when adjacent to Commercial zoning. We also request that the build-to zone match any neighboring property - in Broadway's case, generally C-G-2 - therefore a 0' to 10' build-to-zone. Potential allowances could/should be made for existing churches and historic residences that have been converted to office functions - however this may need to require historic overlays.

Affected Office Properties Along Broadway (and Woodland):

815 N Broadway; 215 Bearden Place (current use noncompliant as office); 901 N Broadway; 949 N Broadway; 826 N Broadway; 830 N Broadway; 834 N Broadway; 1207 N Broadway; 1216 N Broadway; 1303 N Broadway; 1323 N Broadway; 2909 N Broadway; 3101 N Broadway; 3111 N Broadway; 3127 N Broadway; 818 E Woodland; 1306 N Broadway; 2921 N Broadway

Institutional Zoning

Currently institutional zoning does not have a 'build-to' requirement, and requires a 20' front and corner/side setback. This creates a similar condition to the above-mentioned Office zoning setbacks. For institutional parcels within an urban area or along an urban core (such as N Broadway) we request an institutional zone that has no front setback, but a 'build-to' requirement that would force new construction to align with the building face of adjacent C-G or Office properties. This would also force parking to occur behind or to the side of a building, as opposed to in front of it.

Additionally, the Task Force has reservations related to the allowance of Homeless Shelters on Institutional-Zoned parcels. Due to the nuances related to N Broadway with relation to the Homeless, we request that Institutional Properties along N Broadway (especially the current Physician's Regional property) prohibit homeless shelters.

Height Restrictions & Step-Back Requirements

We believe maximum building height should be less related to zone (as in O, C-G, C-H), but where a parcel is located on the map, IE distance from downtown. In general, we would recommend that the maximum building height remain taller (or unlimited) downtown, and then step down outward from downtown accordingly.

We recommend adding a height restriction to CG-3, perhaps 85' with review process if requesting over 85' and 130' maximum with review. The gap between C-G-2's 70' maximum height and C-G-3's unlimited maximum height seems too extreme. An intermediate is necessary, while limiting the unlimited height restriction to DK zones seems more appropriate.

We request C-G-2 (or anything above 4-5 stories, or an appropriate height) to have a 'step-back' requirement, similar to the Cumberland District - whereas any floors above a certain height are required to step back. This will avoid the 'tunneling affect' along the corridor, and is similar to what larger cities like New York City enacted.

I-MU Design Standards

I-MU should require Commercial Design Standards when redeveloped as mixed-use properties. Not allowing such standards would create a loop-hole for I-MU properties developed as mixed use as opposed to CG or DK zones.

We recommend landscape screening requirements for commercial and/or office zones where the rear of the property abut a residential district. We recommend requiring infill commercial to align with existing building frontage/datum established by existing urban (pre-1950s) development.

Parking Requirements related to C-G-2 and C-G-3

Currently proposed is parking requirement reductions for pedestrian-oriented zones, which we agree with. However currently there is a 10% parking reduction for C-G-2, and a 20% parking reduction for G-G-3. We have requested and agreed with current proposals for C-G-2 along N Broadway namely due to the reduced height restraint - which is more in-keeping with a pedestrian oriented zone as opposed to unlimited (or taller) height restraints. If anything, these taller buildings will require more parking to serve their uses adequately, so it seems the reduction percentages are backwards - in that C-G-2 should allow a higher reduction than C-G-3, or it not at least the same.

Therefore, we request C-G-2 allows for a 20% parking reduction to be equal to C-G-3. If this is not possible, we would request a separate C-G-3 subsidiary zone that maintains the higher parking reduction, while creating a lower height restriction.

Homeless Shelters within C-G Zones

We request the removal of Homeless shelters from the C-G zones, believing that their allowance within C-G and C-R zones is sufficient, if not more appropriate.

Floodway Overlay Zoning

The current 'Floodway Overlay Zoning District' is noted as being "established to meet the needs of the streams to carry floodwaters of a 500-year frequency flood," however the map overlay district does not reflect the 500-year flood plain. We ask that you update your map to show the accurate 500-yr flood overlay (see below) to allow current and future property owners an accurate representation of where they will be able to construct new buildings and/or renovate existing structures that may be within the 500-year floodplain.

Because a large portion of properties along the Broadway Corridor are within the 500-year floodplain, we ask the MPC, ReCode, and the City of Knoxville to create and/or utilize any possible zoning or administrative tools to allow for redevelopment within the flood zone, or at least more effectively communicate to property owners the restrictions they are faced with.

As a result of potential miscommunication between the City, FEMA, and property owners, many are easily confused regarding current regulations, since their properties may have been constructed before the 500-yr floodplains (and therefore current restrictions) were established.
Staff Reply:

Recode Second Draft Comments

Section 5.4: Design Standards
- Issue: What does 'substantial repair or rehabilitation' mean? "The following design standards apply tosubstantial repair or rehabilitation meant to remedy damage or deterioration of exterior façade"
- Remedy: more clearly define when design standards would come into play; define 'substantial repair or rehabilitation'

Table 5-2: Commercial Site Design
- Issue: Surface parking location requirements are incompatible with current and reuse/redevelopment of many lots in O, C-N, C-G-2, C-G-3 districts (ex: L-shaped commercial strips, businesses that need loading/truck facilities on the rear of the lot). "Surface parking may not be located between the principal building and the front lot line. Parking must be located to the side or rear of the principal building [in O, C-n, C-G-2, C-G-3 districts]."
- Remedy: Remove this as a requirement and instead use it as a possible incentive in Section 5.3.B and other incentive sections. Staff has recommended incorporating current parking requirements without change; this would be a significant change.

8.4 Hillside Protection Overlay Zoning District
- In order to facilitate reuse and redevelopment of small-scale and larger-scale commercial/industrial areas, apply this overlay only to residential zones.

Table 9-1: Use Matrix
- Issue: "Bar" and "Restaurant" were combined into "Eating and Drinking Establishment" and "Restaurant" was removed as "P" in O and C-N districts. This will transform numerous restaurants from "P" to "S" in C-N (ex: Plaid Apron in C-N, Sequoyah Hills neighborhood) and create nonconformities in O district. It could create more pushback when an "Eating and Drinking Establishment" is requesting "S" in C-N in the future.
- Remedy: Remove "Eating and Drinking Establishment" and reestablish "Bar" and "Restaurant" as separate uses.

- Issue: "Medical/Dental Office" was downzoned from "P" to "S" in C-N. These are currently "P" in C-N.
- Remedy: Return to "P" use in C-N.

Parking and Landscaping
- Please keep with staff recommendation that existing parking and landscaping requirements be incorporated into Recode, and that the landscaping bond be removed.

15.D.3.h Planned Development
- Issue: More clearly define "affordable housing" set-asides.
- Remedy: Provide a threshold of rental or purchase price based on existing market and population data or government guidelines. Do not require "affordable housing" to be government-approved/subsidized.

16.2.D Nonconforming Use
- Issue: "Discontinuation or Abandonment" as it currently reads is unclear and does not reflect general market conditions for reuse and redevelopment of real property.
- Remedy: Provide a definition for "Discontinuation or Abandonment", increase "six months" period to at least 18 months to reflect commercial property general market conditions, and add in a language that being "actively marketed for lease or sale" is not considered "Discontinuation or Abandonment".

Thanks for considering my comments. This is not an easy task.
Staff Reply:

Recode Project

I am concerned that zoning districts which allow for affordable housing have deceased in the new rezoning plan. I especially would like to see more areas which allow for RN3 and RN4 zoning, two new categories created during the ReCode process but not used in the proposed map. This type of housing avoids problems associated with huge housing profects. The RN3 and RN4 units foster more personal and close knit communities and allow for residents to be a part of regular neighborhoods. These units are also a good size which provide smaller developer companies opportunities to build them. Thank you.
Staff Reply:

General Comments

Regarding commercial buildings along the main corridors, glass should be highly transparent on the main floor, and non-residential use should be either required or highly encouraged using whatever zoning tools are available. The buildings should be at least built in such a way as to allow non-residential use on the main levels in the future.

Required materials should be durable and sustainable. No vinyl and especially no vinyl windows.

I do not think the use of paint colors should be addressed in the code (see 5.4B). There are plenty of examples of monochromatic buildings that are beautiful and interesting because of varying types of building materials, etc. In fact, the new apartment buildings at the south end of the Henley St. Bridge (not the orange and gray one, the one across the street on the east side) vary in color so much that from afar it looks very busy, even though the colors are not bold. Furthermore paint colors can be changed and thus shouldn't be considered a part of the structure.

Bike racks should be required for commercial and multifamily residential.

Multifamily courtyard apartments such as common in Chicago on city corners should be allowed (there are actually also many examples of these in Fort Sanders and East Knoxville) in high and moderate density neighborhoods, with high quality of materials (brick mostly) and good form so it is a contributor to the neighborhood fabric.

Thanks to MPC for all your work on this.
Staff Reply:

Put Back The Orange

Put Back the Orange, Put Back the Orange, Put Back the Orange...we need more - not less - affordable multi-family housing in Knoxville. Put Back the Orange.
Staff Reply:

Put The Orange Back! Add The Tan!

We need MORE affordable housing in Knoxville, particularly RN3 and RN4! We have over 20,000 of our families paying more than 50% of their income for housing costs. I'm hopeful that as our community leaders, you recognize we clearly have a crisis in affordable housing in our community. Instead of being a responsive, conscience-centric approach, the new proposed map from the ReCode process appears to actually reduce the potential to build affordable housing in Knoxville!! Please, please redesign the map! Let's Recode in a manner that honors our community and seeks to serve all of our citizens. RN3 and RN4 would encourage more affordable housing in already-existing neighborhoods, which would be a GOOD approach. Thank you for including the Orange along the more accessible corridors, however we still need more of the higher-density zoning, too. Knoxville is a wonderful place to live, let's make that true for all of our families.
Staff Reply:

Proposed Rezoning

Put the orange back in!! We need more and not less.
Staff Reply:

Comments On Some Survey Questions

Not just new but renovated buildings along any corridor should be required to have a buffer whether trees, bushes, or a well maintained attractive fence. Alley ways between buildings and residential are usually unkept. Some vegetation, trellis work or partial fencing could help between residential and other uses. Strict regulation of noise from both music, parties or food trucks generators, commercial docks and smoke from any source that intrudes into residential should not be allowed.

There are some reuses that should not be allowed in old buildings. But, a restaurant is a more intrusive use than a warehouse just in looking at the operating hours. While a homeowner may work during the day and not notice a warehouse during the day. The restaurant business hours of operation occur during the residents evening down time or kids bedtime. Anytime alcohol is part of the picture there is high likelihood of loud voices and inappropriate language. Lighting is becoming an issue as added street lighting occurs along with signage and lighting added as decoration at night. Car noise, fumes, and parking with people coming and going is intrusive to a family quiet time so operating hours should be restricted. The type of business is very crucial to residential stability.

The reuse of an existing building should fit with the neighborhoods character. This does not mean there should be a bar on every corner. No industrial. Enough parking to stop parking carryover on to residential streets. if code requires a building height of 4 stories there should be a clause that 4 is a recommendation but if development wants less height say 2 story that would be allowed, but not higher. Supporting infrastructure, sidewalks are the developer's responsibility since many want TIFs or PILOT breaks for 20-30 years at taxpayer expence on pensions, road maintenance and other services.

ADUs and STR should be restricted to only homeowner occupied with off street parking. in EN, RN-1, RN-2, and SW-1. With no subletting greater than the allowable number on the lease per unit or fire code/ occupancy limit.
Staff Reply:

Comments For Todays Recode Workshop

Hello, please include the attached letter from Town Hall East, Inc. Board of Directors in today's workshop packet. Thanks!

Sharon Davis
Town Hall East, Inc.
Staff Reply:

Comments On Recode Knoxville

Having looked over the Recode book available at the library, here are my comments, in order of the numbers at the bottom of the page.

4.4 EN zone - requires more than one finished floor, this ignores retirees who want to be in an estate type neighborhood and seek one level living. I understand specifications of more than 4 wall sections but feel 6 is a sufficient minimum if the variation is visible from the street.

5.26 SW3 - Do not remove the section about "existing buildings will be encouraged for reuse". This is consistent with the march 2003 Vision Plan "feeling like a Main street and serving folks on both sides of the river, providing a place to buy a gallon of milk and a loaf of bread, meet friends for coffee..." "small markets and shops..." (page 30). I like the eclectic nature of the businesses on Sevier Ave and fear that new construction would have rents so high they would only house chain establishments.

5.27 SW2 - Your draft shows a minimum of 0 and maximum of 10 for the front setback. There is a section of SW2 on Scottish Pike east of the railroad that fronts onto a SW1 zone. A development with these setbacks would harm the "small town neighborhood atmosphere" found in SW1. I am requesting that the front build-to zone be changed to a minimum of 15' and a maximum of 20' in this area. The minimum build-to frontage is much higher than the other zones and should be reduced to 50 or 60%.

8.3 NC district. I am glad you retained this as well as the historic overlay.

9.6 and 9.7 - I am very concerned about restrictions on vinyl siding to 15% for townhouse and apartment developments. Furthermore the materials on the front must wrap around to the sides. We need affordable housing for people to buy or rent without being restricted to subsidized housing. New construction is a way to provide energy efficient unsubsidized housing but it needs to use affordable materials. The effect of these restrictions is that entry level multi housing will be constructed outside the city limits, furthering traffic congestion. I have heard people say that supply and demand will create affordability. My mailbox is filled every week with letters and postcards from flippers wanting to turn affordable housing into unaffordable housing. If aesthetics are a concern along the corridors, that can be addressed in the corridor plans.

10.4 ADUs - I am generally in favor of ADUs but there are valid concerns about ADUs in the RN1 district. I am OK with ADUs in the EN district as these are owners most likely to have a housekeeper, caregiver or au-pair. I am fine with ADUs in the RN2, RN3, etc districts but they need to be counted as an additional unit and parking issues need to be considered, will there be enough street parking, etc.

12.4 to 12.6 - I like trees in parking areas and would prefer 1 tree to 20 spaces as opposed to 1 tree per 30 for the interior rows. The requirement of an island being exactly the size of a space is too restrictive, better to specify a minimum s.f. per tree in an island. Peremeter trees are good, I am concerned about shrubs on the peremiter making a parking area feel less safe. Groundcover in the islands is likely to look ratty and should not be required. Installation sizes of 4' evergreens and 1.2" caliper will give the trees a better chance of survival.

12.9 - I like very much that you are encouraging existing trees to be saved.
- 20% is a big change in grade. That needs to be redefined.

Thank you for your consideration
Staff Reply:

Recode: Draft 2 Comments

Bring back the Orange by better utilizing the newly created RN-3 & RN-4 (as well as RN-5 where appropriate) districts that more appropriately represent the existing development patterns of the neighborhoods where it was removed.

Projected population growth will necessitate "Orange" neighborhoods along corridors & with access to transit.
This is inline with ReCode Section 1.2 Purpose statement - to promote economic development that balances the needs of current & future economy; utilize existing infrastructure & resources.

Down-zoning current R-2 to proposed RN-2 reduces options for medium density redevelopment and doesn't reflect the existing development patterns. This reduction also further promotes financially irresponsible development patterns, leading to more sprawl, traffic, and infrastructure expenses without increasing the tax base to support it. This reduction goes against the vast amount of experts that have been brought into our community as speaker. (i.e. Joe Minicozzi, Chuck Marohn, Jana Lynott, Jeff Randoph, and more).

Dwelling Design Standards: Single & Two-Family

As written, we're moving in the right direction. Standards MUST be objective & easy to understand and navigate. There are still some subjective wording within the standards that should be clarified. A Design Standard "Checklist" would be helpful. The Downtown Design Review Board could be used as a model to be duplicated for areas with Historical significance comprised of unbiased professionals.


Too restrictive for Duplex (as written requires 2 spaces/du = 4 spaces). Requirement should consider number of bedrooms I.e. Duplex w/ a 2 bedroom unit + 1 efficiency unit. How does the code interpret a 40' single-width driveway.. 3 spaces? Need more clarification for what will actually be required to meet residential parking space requirements.


As written, Lot area minimum of 5000 sq.ft. is excellent & best practice. As written, Allowing attached or detached is excellent & best practice. Side setback of 8' and rear setback of 10' are too restrictive for small lots.
In areas where ADUs are most needed (in or near transit-oriented development) residential lots often range from 50 x 100-150 feet. A 10' setback requirement makes detached ADU placement extremely challenging on small lots. In walkable urban neighborhoods, setback requirements should be kept to a minimum to enable detached ADU development: 5 feet is a reasonable setback requirement for such lots. As written, ADU setbacks are more restrictive than the setback for other comparable accessory structures, such as garages.

Setback regulations for detached accessory structures may also consider tiered standards based on the detached structure's height, to protect light and air for adjacent lots. Basic design standards such as no low windows or doors are allowed within the sides of the structures that are within 5 feet of the property line. This nuanced, tiered setback approach protects neighboring properties' light, air, and privacy while affording smaller lots the same development entitlements as larger lots. It is the same development standard that applies to garages and other accessory structures.

Limits to Max gross floor area.

Capping ADU size is useful at responding to market needs for smaller dwellings. A reasonable cap should be smaller than the primary structure. However, adequate cap size would allow for two people to comfortably live. We need to ensure that ADUs can be at least up to 600 sq. ft. Many cities have a floor area ratio between the main house and the ADU that restricts the ADU to 300â€" 400 sq. ft. That does not work for someone who is fifty-five and has lived in a single-family home for decades. 300-400 sq.ft. doesn't work for a couple who is going to have a kid and going to live a normal life with friends and family that come and visit.

A home that is 600 sq. ft. can function as a real home by the standards of what people want & expect from a home. The cap SHOULD NOT be tied to the existing floor area ratio of the primary structure.
For example, a standard 800 sq.ft. post-war cottage (abundant in our urban neighborhoods) shouldn't be restricted to a 320 sq.ft. ADU. With current building codes not allowing sleeping lofts, it's quite difficult to adequately provide all that is necessary for a dwelling within such a small space. The cap SHOULD BE tied to Lot Size (as written) not to exceed the primary dwelling. A 600 sq.ft. ADU should be allowed on a 5000 sq.ft. lot even with an 800 sq.ft. primary structure. The 40% cap of primary dwelling should be removed from the code.

Omit or clarify the subjective statement #9. The ADU must be designed so that the appearance of the primary structure remains that of a house.

As written, no additional parking requirement is excellent & best practice.
Staff Reply:

Climate Knoxville Recode Knoxville Comments

Climate Knoxville submits comments and background information on the current draft of Recode Knoxville.

Louise Gorenflo
Climate Knoxville
Staff Reply:

Put Back The Orange

To whom it may concern

I am a resident of Knoxville and spend a lot of time in east Knoxville. I am really glad to see the work being done on Magnolia but I am definitely against changing the zoning along Magnolia to single family. I think this will create many hardships for people living in this area and even impact transit service.

Thank you for taking this into consideration.
Staff Reply:

Recode Knoxville

Please put back the orange. Keep it. We need flexibility for affordable housing. I wish everyone could have the option of single family dwellings. However that is not possible nor wanted. We need zoning maintained for duplexes, four plexus, etc. as well as developments with 100's of units for affordable housing.
Staff Reply:

Park City Preservation Alliance

The Park City Preservation Alliance (PCPA) is a not-for-profit organization dedicated to the preservation of the places, stories, history, and culture of the people of, in, and near Historic Park City, Tennessee.

The PCPA Board of Directors have agreed on the following recommendations for ReCode:
1. OS-1 should be retained as an option to conserve historic, archaeological, and cultural values of open space, rather than merged into the new OS that does not reflect these important land uses.

2. The Historic Zoning Commission should be granted authority to allow variances for rehabilitation and habitation of documented historic accessory structures that may be non-conforming under new zoning ordinances.

3. The Historic Zoning Commission should be granted authority to allow variances to permit re-building of the foundations of lost, documented historic accessory structures to allow future, code compliant construction of habitable accessory dwelling units.


Park City Preservation Alliance Board of Directors
President, Greta Schmoyer
Vice President, James Waldrup
Treasurer, Ed Strickland
Secretary, Tanner Jessel
Staff Reply:

Recode Comments - Broadway Corridor Task Force

Good Evening

Thanks again for meeting with Kyle and me a few weeks ago to discuss ReCode and its affect on the Broadway Corridor. As you may have seen, we have been submitting map-related comments over the past few weeks. However as we discussed in our meeting, we compiled a document with all of our general code and map-related comments, and attached that document to this email.

If possible, would you mind having someone on your team go through the attached document to make sure each of the comments (specifically, the map related comments) were submitted and/or taken care of? We spent a good amount of time getting all of these comments together and they developed over time so some of our previous comments may need to be updated, and we would hate for some of the comments to be lost (it became hard keeping track of what was submitted, and what was not).

Thanks again for all of your hard work in coordinating this effort, and we apologize that we are submitting these comments right up against the deadline! If you have any questions please feel free to reach out to me.

Jimmy Ryan
Kyle Anne Lang

Broadway Corridor Task Force
Staff Reply:

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