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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Thanks for speaking with me at the Saturday Recode community meeting. As per your request I am sending you an email regarding my questions and points. I indicated to you I had read the entire draft ordinance and generally liked it, but did not think any one zone encompassed the full amount of current uses and desirable future uses in some of the current central city sector plan zones, specifically I am talking about some of the MU-SD districts that currently have a mix of what would be considered RN-4 to RN-6, O Office, and C-N Neighborhood Commercial uses under the new ordinance. I indicated I thought it was desirable for the city and the property owners for this to continue. I like the idea of fostering small neighborhood markets or cafés which makes the neighborhood nicer and gives the residents the ability to walk to some small scale basic retail services. I suggested a simple solution would be to make some of those MU-SD districts RN-6/C-N neighborhood commercial, for example, as it would cover the existing uses and control future growth according to the design standards in the new ordinance. You would not need to change anything regarding the proposed table 9-1: USE MATRIX as in my theoretical district you would look down the RN-6 column and C-N column and those are the permissible uses, of course you would need to meet all of the design requirements for the use you wanted. I chose C-N because according to the Matrix everything allowed in O Office is allowed in C-N so those current and future uses are covered. As I have consistently stated I like the idea of redoing the zoning ordinance code to make it more simple and clear and don't mind design standards but do not support decreasing my current property uses or future uses that I am allowed under the current zoning ordinance, I don't think that is good for me or the City as it looks to the future.

We also discussed Table 4-1 and that RN-4 had a minimum lot width of 50 feet but RN-5 and RN-6 had a minimum lot width of 60 feet. Perhaps it is a typo, but in any event, I stated they should all be 50 feet. Additionally, we discussed section 4.3 that requires multi family housing in RN-4 zones to be on only corner lots. Knoxville already has successful examples of where multi family dwellings are in the middle of a block amongst single and 2 family dwellings and are less obtrusive overall for the block then a corner location. Knoxville will benefit from fostering a heterogeneous mix of dwelling units ranging from single family to multi family within these MU-SD districts, which I recognize each has different characteristics and will require different variations. These varied housing types will attract and provide housing to a wide socio-economic range of people, plus the density will help support C-N businesses. Having traveled to other cities these types of neighborhoods are dynamic, very attractive, and walkable. Having design standards, as the new ordinance does, will make these varied uses fit together in an aesthetically pleasing manner.

Thank you and the planning group for your consideration of my prospective. I look forward to any feedback you and the group can give me.

Kcdp Pac Comment Submission On Recode Knoxville Draft 1

On behalf of the Knox County Democratic Party Progressive Action Committee, we would like to submit the attached comments on ReCode Knoxville Draft One.

Please let us know if you or your team members have any questions on our submission.

Thank you,

Progressive Action Committee
Knox County Democratic Party

Recode Support

I am definitely in favor of the recode as one much needed measure to address the crisis in affordable housing.

Recode - Adus

I would like to write in favor of ADUs being allowed in the Recode plan. They can provide alternatives to affordable housing, which we so desperately need in Knoxville.

Naacp Recode Knoxville Comments

Attached please find comments from the Knoxville Chapter of NAACP on the 1st draft of Recode. Amy Brooks informed us that we could submit our comments by the end of this week for consideration before the 2nd draft. If you have trouble opening the attachment, please let me know. Thank you so much for your consideration.

LaKenya Middlebrook
NAACP, Knoxville Branch
Housing Committee

Tree Mitigation

I would like to suggest Knoxville consider developing and implementing some form of mitigation for the destruction of trees by developers, perhaps along the lines of how TDEC operates its stream and wetlands mitigation program. In the case of tree protection, the ordinance could specify that for each tree destroyed over a particular dbh, X number of trees of 2" caliper have to be planted; or, a value of the destroyed trees could be established and the developer pay the equivalent value into a mitigation bank, with the city using the funds for planting or landscaping projects.

Harvey Broome Group
Sierra Club

Olpna Comments

I'm forwarding the comments we've come up with for submission from the Oakwood Lincoln Park Neighborhoods Association. (View Comments) We would also like to suggest that the comment posting be open for another few weeks as many residents are just now hearing about Recode and are still trying to assimilate all the information. Thank you.

Feedback From A Discussion At The Food Policy Council

The Knoxville-Knox County Food Policy Council has NOT voted on a recommendation at this time and date. They individually have provided some general feedback to some City and County in advance of the deadline which I am summarizing below:

They are supportive and in favor of changes regarding food, farmers markets, and urban agriculture as included. There were concerns about ambiguity of farm stands/seasonal produce stands and ensuring the language is clear and consistent in references. They also felt like it may be beneficial to have a presentation from the consultant on specific food-related items in the next phase.

Compliance With Landscape Ordinance Requirements


In regard to compliance with Landscape Ordinance requirements, based on discussion with those professionally qualified to understand both the value of proper landscaping for any development and the challenge of achieving compliance, the two-step LANDSCAPE BOND makes a lot of sense.

1. PERFORMANCE BOND: It essentially allows developers six months after issuance of the C O to install landscaping, to offset the disadvantage of completing projects in late spring or summer months, to assure reasonable growth conditions and released upon satisfactory compliance, as determined by a landscape architect familiar with the design intent.
2. MAINTENANCE BOND: Applicable during the two-year period following the project's completion and including a reasonable time period for proper landscape care to assure healthy plant material following that period. The Maintenance Bond is released after two years, contingent on satisfactory inspection by qualified professional, a landscape architect licensed in Tennessee and familiar with the design intent.

Opposition To Adu And Restaurants In Office Zone

I live in a historic neighborhood in Fountain City currently zoned R-1 where permissive rezoning rules have allowed commercial encroachment. significantly increased traffic, and detrimentally altered the way of life on my street. Therefore, I am voicing opposition to allowing accessory dwelling units in R-1, even under the special use permission. I am also voicing opposition to permitting restaurants in office zones as outlined below.

1. Accessory Dwelling Units- After attending the recent Recode Knoxville open house, I learned that Accessory Dwelling Units (ADU) are proposed for current zones R-1 (new zone RN-1). At a minimum, new ADUs should be prohibited from RN-1 as they have a extremely high likelihood of altering the character and driveability of single-family neighborhoods. As has been shown in the past, garage apartments, mother-in law suites and similar ADUs become permanent structures once the capital expenditure to build or renovate accessory space has been made. This means a permanent increase to housing density and a permanent increase to traffic and possibly to on-street parking. A temporary structure for special needs cases would be acceptable, but not rezoning to permit ADUs. Tennessee law currently allows for TEMPORARY housing to be constructed on any qualifying residentially zoned land to care for an elderly/needy relative. Once the need no longer exists, the law requires such special needs structures to be decommissioned.

2. Our neighborhood supported office zone O-1 for some structures to be used as a buffer and transition between more heavily used commercial and our residential neighborhood. There are more than sufficient suitable locations for restaurants in Knox County without jeopardizing residential areas by allowing restaurants in an office zone. Restaurants have significantly higher traffic throughput and extended business hours in evenings and weekends than offices and would, therefore, not provide an adequate buffer to residential neighborhoods. Please do NOT allow restaurants in the office zone. This would not provide an improvement to the zoning in Knoxville. Quite the opposite!

(no Title)

I apologize for not having the time to give more specific feedback, but I wanted to send a few comments. I support the allowance of ADUs in the zoning. They are an important, responsible, and effective means to increase density and provide affordable housing stock. I support the landscape requirements as I feel they are important to improving/maintaining life quality in our city. I support the neighborhood commercial zone, particularly because it may open up opportunities for increased food access in areas that currently may have poor access to quality food options. I hope to be able to offer more specific feedback on the next draft. Thank you for your efforts. I am generally pleased with the direction of ReCode Knoxville. One area of concern is the potential elimination of the Downtown Design Review Board. I think this board process allows public input into projects that might otherwise have little public notice or oversight. I would prefer to see the DDRB continue to exist.

Tree Protection Ordinance

Knoxville has a Tree Protection Ordinance. Is there a reason why this wasn't included in the Recode draft?

Also, rather than saying invasive plant species aren't allowed, can the ordinance link to a list of invasive species and state that anything on the list is prohibited?

Recode Koxville Comments

I speak on behalf of the Sierra Club's ~1,000 members who reside in Knoxville. We thank you for the opportunity to comments on the proposed ordinance and provide the following comments:

1. Article 3 - This may or may not be the appropriate place, but since it contains Special Purpose Districts and Overlay Districts, it seems fitting. The proposed Ordinance contains no reference to, or any part of, the Hillside and Ridgetop Protection Plan. The Plan was adopted by City Council and incorporated into the General Plan in 2011. In 2017, the City determined that, except through Use on Review, and the Use on Review Development Plan process in Planned Zoning Districts, (Planned Commercial, Planned Residential, Shopping Center), the City's adopted Hillside and Ridgetop Protection Plan could not be enforced. The reason given for why the Hillside and Ridgetop Protection Plan could not be enforced is that the Plan had not been codified. The failure to codify the Hillside and Ridgetop Protection Plan left the Use on Review Development Plan process in Planned zoning districts as the only enforcement mechanism. Therefore, the removal of the existing planned zoning districts results in there being no mechanism to enforce the Hillside and Ridgetop Protection Plan.

The City Administration should immediately support and the City Council should prepare and adopt a Hillside and Ridgetop Protection Ordinance so that the adopted plan can be enforced.

2. Article 11 - The current parking ordinance allows for reduced or no perimeter or interior landscaping for lots smaller than 20,000 sf. All lots larger than 5,000 sf should be required to have some perimeter landscaping. Lots between 5,000 and 20,000 sf should be required to have graduated interior landscaping (smaller and/or fewer islands), depending on size of the lot. Additionally, we recommend lot sizes be calculated in terms of parking slots rather than square feet; this would be easier for developers, and the public, to interpret. Lots larger than 20,000 sf should have a landscaping break every 10 spaces rather than every 15 spaces.

In general, there should be a greater emphasis on stormwater management (as well as shade distribution) when considering the placement of landscaping in parking lots. Better stormwater treatment can ultimately reduce costs to developers.

Plans Review and Enforcement - This is a major concern to everyone. Ultimately, enforcement will be determined by the will of the city administration and staffing, no matter what's written into the ordinance. We think it's important to have a credentialed professional staff oversee the approval and enforcement of landscape plans.

Tree selection is tied to a list of approved tree species maintained by the Tree Board. However, shrubbery selection is left to the developer, although native and naturalized plantings are recommended. To insure high quality, we would like the ordinance to tie selection to an approved list of recommended shrubs, grasses, ground covers.

3. Article 12.10 - This Article as written is inadequate. We would like to see the current Tree Protection Ordinance (Chapter 14) incorporated into the proposed Ordinance.

Comments On The 1st Draft

Thanks for your work on this draft, I am generally supportive of the new language and structure, and hope it will help promote sustainable and equitable growth for years to come. As a Public Health Educator focusing on food access in Knox County, most of my comments have to do with food-system related uses and language.

Food Pantries: I would like to see them permitted in more districts as a principal use. Restricting them as an ancillary use to places of worship, social service centers, etc. hampers their ability to combat food insecurity in nimble, efficient ways.

Food Truck Parks: I approve of this new principal use, though it would be nice to see it permitted in additional districts, either flat-out, or by special use.

Market Gardens: Please make it easier to locate market gardens in residential districts, either by allowing them as a principal use, or making the special use conditions/fees more manageable. The majority of market gardens will inevitably spring up in residential areas (backyards, vacant lots, etc), but a cumbersome special use application process will deter many would-be urban farmers. I fully support the environmental performance standards, but I think many of the concerns regarding the occurrence of market gardens in residential areas have to do with traffic generated by on-site sales, which should be covered under the Farmstand temporary use permit. We need to encourage the production of food and the generation of small-scale local economy and business everywhere we can! Codes enforcement can keep these sites in compliance without creating so many hoops for these gardeners to jump through on the front-end.

Neighborhood Nonresidential Reuse: I am very supportive of this addition because of its potential to help address food access in residential areas, and to stimulate innovative and convenient mixed-use neighborhoods.

Farmers Market: I approve of this new temporary use, though it would be nice to see it permitted in additional districts.

Farmstand: I approve of this new temporary use, but would like to see it allow year-round sales, either by allowing a 12 month permit period, or allowing for re-application immediately following permit expiration. Season-extension equipment (referenced in this draft) and a generally temperate climate make year-round vegetable production a viable, and often vital, practice. This is evidenced by the proliferation of winter-season farmers markets, and year-round CSAs offered by local growers. These benefits should be extended to urban producers and market gardeners as well.

Composting: I recognize that much of this language is dictated by state regulations, but wherever possible, I would like to see composting made more accessible and convenient on both the residential and municipal scale. Food waste is America's dumbest problem, and language that can promote, or at the least get out of the way of, composting activities should be supported. Item 4 "enclosed or contained" in the composting section is contradictory to the previous three items "bins or piles". Piles are a viable and convenient method of composting but are not "enclosed of contained".

I am supportive of the language regarding: Apiaries, Aquaponics and Hydroponics, Chicken Coops (though I would like to see the hen ordinance made less expensive and complicated), High Tunnels and Greenhouses, and Low Tunnels and Cold Frames.

I am very supportive of the addition of Accessory Dwelling Units to the code. In light of the affordable housing crisis both locally and nationally, ADU's offer a great alternative option for affordable housing in a market that is swiftly pushing out many low-income renters, as well as offering income generation for homeowners and increasing urban density.

I am very supportive of the landscaping requirements for new development.

I almost certainly did not cover all the topics in this draft that affect food access, but hope that any changes to the code promote a healthy and sustainable food system in Knoxville and Knox County.

Community Forum, Supplemental Response To Recode Knoxville, Draft 1, 5-20-18

Community Forum is submitting its first Supplemental Response to the first draft of Recode Knoxville.

This Supplemental Response covers our 14th topic, Office Zoning District, (Article 5).

Thank you for your consideration.


Larry Silverstein, Secretary-Treasurer
Community Forum

Re: Recode Knoxville

Our neighborhood, Tazewell Pike-Beverly Station Neighborhood Coalition, would like to voice our objections to at least the 2 items listed below:

1. Accessory Dwelling Units- we feel at least SOME zones, preferably existing zones of R-1, R-1E , and EN-1 and EN-2, should be excluded from the proposed permitted use of an accessory dwelling unit. If implemented that provision has the potential to completely change the character and density of our neighborhood. Also, our roads are not equipped to carry that additional traffic and there are no mass transit stops within easy walking distance. We like the large lots and open spaces- that is one reason we bought homes here.

2. We supported office zone O-1 for some structures to be used as a buffer and transition between commercial and residential. If restaurants are allowed in office, you have defeated the purpose for office zone. We would have tried our best to fight the rezoning to office in several areas near our homes if we had any idea that restaurants would be allowed. Please do NOT allow restaurants in the office zone.

We bought our homes depending on the zoning that was in place and hopeful that any changes in zoning would serve to only enhance our neighborhood, not completely change it and possibly alter it forever.

We are disappointed and upset about these 2 proposals in the recoding. This is NOT a step forward for our neighborhood- it is 10 steps backward!

Jamie Rowe,

President, Tazewell Pike-Beverly Station Neighborhood Coalition (R-1 with an NC-1 overlay)

General Comments

I attended the workshop held in Fountain City on May 17th and was favorably impressed with the overall direction of the Recode effort. In general, I am supportive of the continued inclusion of the areas supportive of urban agriculture and food (expressed separately through comments with the Food Policy Council). Specifically, I am in support of the Accessory Dwelling Unit/lot proposal and of the increased/enhanced landscaping requirements. Thanks for everyone's efforts on this major project.

Landscape Requirements In Recode

Here are some comments on the proposed ordinance concerning landscaping requirements.

First it is important to have adequate resources including staff to review proposed plans and to enforce the requirements of any ordinance or the purpose and intent of the ordinance will not be accomplished. It is recommended that new staff be added to review and follow up on the landscaping requirements. This staff should have the required education and training to adequately ensure the compliance of all project plan to follow the requirements of the ordinance.

How does this ordinance impact the existing tree protection ordinance and requirement for historic tree protection? If the new ordinance has been written to include the existing tree protection, then it doesn't provide adequate coverage. If the new ordinance wasn't intended to include requirement of the existing tree protection ordinance, then how will they work together?

How does the new ordinance incorporate the Hillside and Ridgetop Protection Plan which was adopted by City Council and incorporated into the General Plan in 2011?

Is the requirement for 8 trees per acre adequate to sustain the goals of the city to maintain and protect the urban forest canopy? What information was used to establish this requirement?

Screening seems to be the primary focus of the benefits of vegetation but there are many benefits provided by tree and shrubs and this should be included in the goals and requirement of the ordinance such as improved water management and air quality at a minimum.

Alternative compliance should provide for other ways to meet the public interest in protecting and increasing urban tree canopy and the ordinance should include ways to bank these benefits by providing for methods to mitigate negative impacts that can't be avoided on site. An example would be utility requirements that trump preservation or planting requirements should be offset by purchasing credits to be used at other sites for the public good.

When trees are preserved, the trees preserved should have adequate root protection to ensure survival and this requirement needs to be included in the ordinance.

Important that the city's list of trees is included in the ordinance as a guide for tree selection and other list of the city should be included which indicate native species appropriate for Knoxville could be referenced as well for shrubs, flowers and vines.

Long term maintenance and protection of required trees could be included or recommended to prevent future loss due to clearing and poor practices such as topping or poor mulching.

The ordinance should look at lists of other plants like those considered invasive, recommended native shrubs, flowers, grasses and vines that the developer could use in planning their project similar to the list of recommended trees.

The current parking ordinance allows for reduced or no perimeter or interior landscaping for lots smaller than 20,000 sf. All lots larger than 5,000 sf should be required to have some perimeter landscaping. Lots between 10,000 and 20,000 sf should be required to have graduated interior landscaping (smaller and/or fewer islands), depending on size of the lot. Lots larger than 20,000 sf should have a landscaping break every 10 spaces rather than every 15 spaces

Forest Heights Neighborhood Draft 1 Comments

The following is feedback from Forest Heights Neighborhood. We have created a focus group of neighbors (including both FHNA board members as well as other neighbors not representing the board) to analyze and discuss the proposed ordinance and how it affects our neighborhood. The members of the committee were: Jim Pryor, Amy Hathaway, Martie and John Ulmer, Joe Hickman, Leslie Badaines, and Amy Midis. Thank you!

Uses Permitted in the RN-1 District:

1. Home Occupations is broadly defined in the proposed ordinance and specific standards previously used to in the current ordinance to differentiate Home Occupations from Home Offices have not been incorporated into the draft. We feel that the current definitions and their standards for both Home Office and Home Occupation should be added to the proposed ordinance.
2. The definition of a Group Home should be more detailed and should be allowed only as a special use in all residential districts.
3. The existing draft permits Day Care Homes in all residential districts. The State currently regulates Group Day Care Homes (8-12 unrelated children) and Family Day Care Homes (5 - 7 unrelated persons up to age 17). Our existing ordinance defines "Day nursery: private" as having 6 or more unrelated children, therefore allowing fewer that 6 children by right. We request that the Day Care Homes be defined in the new zoning ordinance as 6 or fewer children, and a separate classification of Day Care Homes be defined and allowed only as a "Special Use" in all residential districts.

Zoning Request for 4002 - 4216 Sutherland Avenue:

1. The properties from 4002 Sutherland Avenue west to 4216 Sutherland Avenue are currently zoned either Residential or Office. Since residential houses in Forest Heights are located across the street from these properties, the intensity of the use of these properties directly affect our neighborhood. We recommend that the businesses currently zoned O-1 retain their "O" or Office zoning and the single family residences are zoned the same residential zoning designation as our neighborhood.

Administrative Modifications:

1. The Zoning Administrator is given authority in 15.4C to grant a 10% or less modification to any zoning district dimensional standard in this Code. We request that for modifications granted in residential districts, that the adjoining neighbor who could be affected by this approval be notified in advance of its approval. This is most important with regards to setbacks and maximum height restrictions.

Neighborhood Advisory Council Draft 1 Comments

The following is feedback from a focus group created from the members of the City of Knoxville Neighborhood Advisory Committee (NAC). The focus group members were Rob Glass, Anna Compton, Molly Conaway, Jennifer Reynolds, and Amy Midis. Thank you!

Comments Regarding Recode Knoxville
Neighborhood Advisory Focus Group
Members: Anna Compton, Molly Conaway, Rob Glass, Amy Midis, Jennifer Reynolds

1. We feel that the minimum lot square footage for the EN-1 residential district should be reduced from 22,000 square feet to 20,000 square feet. (Article 4.3, Table 4-1)
2. We feel like allowing ADUs on lot sizes of 5000 square feet is too small, and recommend the lot size be increased to a minimum of 7000 square feet. (Article 10.3B)
3. The existing draft permits Day Care Homes in all residential districts. Since no specific standards are provided regarding this use, it appears that regulatory control of these businesses is by the State of Tennessee. We would like to see the draft include local standards for Day Care Homes in the ordinance and not let the State dictate the intensity of this use. Furthermore, we would not permit day care homes that allow more than 6 children not related to the owners. (Article 2.3)
4. We like the idea of non-residential reuses being allowed in the new draft, however, we would like to see the new buildings be updated to new code standards, as well as installing buffers to help distance the property from residential properties. (Article 9.3W)
5. We request that the Class B buffer require one evergreen ever 10 feet, and not ever 20 feet. (Article 12.9C)
6. We request more graphs or pictures in the ordinance to visualize the concept of ADUs. (Article 10.3B)

Parking Lot Landscaping Requirements

Trees Knoxville's mission is to preserve and increase the urban tree canopy on the private and public land of Knoxville and Knox County.

The board of Trees Knoxville has voted to endorse the following statement:

The benefits of trees and landscaping are well known. A few of these assets include beautification of public spaces, reduced stormwater runoff, reduction of air pollution, and cooler ambient temperatures and shade - both of which enhance walkability.

The current parking ordinance allows for reduced or no perimeter or interior landscaping for lots smaller than 20,000 sf. All lots larger than 5,000 sf should be required to have some perimeter landscaping. Lots between 10,000 and 20,000 sf should be required to have graduated interior landscaping (smaller and/or fewer islands), depending on size of the lot.

Lots larger than 20,000 sf should have a landscaping break every 10 spaces rather than every 15 spaces.

Landscaped buffer zones between parking lots and residential development should be 15' wide rather than 10' wide.

Tree selection is tied to a list of approved trees maintained by the City Tree Board. To insure high quality, a similar list should be specified for the selection of shrubs, grasses, ground covers, etc. Both lists should be tied to landscaping requirements throughout the Recode ordinance.

Thank you.

Tree Topping In H-1 Historic Overlay Zones

It would be very difficult to outlaw the practice of Tree Topping for the entire community. However, it may be possible to outlaw the practice in the H-1 Historic Overlay Zones of the city.

Topping in the sense of old time round over cutting of branches, removing most, if not all of the crown of trees in a manner not consistent with International Society of Arboriculture ANSI rules pertaining to tree pruning.

-This practice devalues trees and properties.
-This practice shortens the lives of otherwise healthy trees.
-This practice opens healthy trees up to future decay, rot, and hollow.
-The practice is not considered proper tree work within modern practices.
-This ordinance would pertain to all trees, of all sizes except fruit trees being pruned for fruit production.

It also would exempt old trees being vetranized in an effort to save them. This would be done with the authorization of the Knoxville City Arborist on a case by case basis.

Recode Comments

My hope for Recode is to lower the barriers of entry for small-scale, community based development of affordable, efficient, and sustainable dwellings optimizing the density our existing neighborhoods.

A few suggestions for doing so...

Allowance ADU's:
-if ADU's remain contentious in some neighborhoods.. perhaps they could be allowed in RN-1, 2, 3, 4, etc. and not in EN.
-if contention remains consider utilizing the model ADU code developed by leading experts in the field (available at

After ADU's, a duplex is the lowest hanging fruit for small-scale community-based development. Consider lowering barriers of entry to duplex development, its a great tool increase sustainable density & diversity within existing neighborhoods. Suggestions as follows...

4-2: Consider revising "Minimum Interior Side Setbacks" to allow for small-scale development of duplex properties. Many communities that could benefit from additional density provided by a duplex contain 50' lots (and sometimes less). As written, side setbacks of 20' are counterproductive to a feasible shotgun duplex. Height requirements limit a stacked duplex. Design restrictions limit a "front/rear" duplex where both doors must face the frontage road. Less restrictions will be needed to fully utilize duplex development as a tangible solution for density & affordability.

Also, what would be the requirements for special allowance of Duplex in RN-1, RN-2?

Additional Comments:

4-2: 4.3.C.1 - Why would multi-family dwellings be LIMITED to corner lots only? What about double or triple interior lots, etc.?

9-15: W. Neighborhood Nonresidential ReUse - consider new builds and/or structures for Non-residential use at certain intersections within residential districts. Increase the availability of neighborhood stores, increase diversity, decrease auto-dependence, etc.

10-4: 8. Accessory structures cannot contain cooking facilities or plumbing? This seems heavy-handed and not conducive to resilient, adaptable structures. Garden shed, painting studio, pool house, etc. Plumbing + bathrooms should be at the owners discretion.

11-6: Dwelling - Two-Family = 2 parking spaces per dwelling unit... total of 4 for a duplex. Consider REDUCING to 1 per dwelling unit to not further hinder small-scale, community-based development.

Recode 1st Draft Comments From Kaar Focus Group

Here's what I have:

1. Most of the feedback that I'm getting from folks is that there's a disconnect between codes and the fire marshal (which isn't really cogent to this conversation). The general theme as that we need to make things as clear as possible and that the administrative folks all need to be on the same page.

2. Overall, I am very optimistic that these changes will improve our city, so thanks for your work on contribution. Here is my feedback from reviewing the first Draft of ReCode:

Overall, I am in favor of increasing higher-density options in RN-1,2, & 3 neighborhoods - with special use, if developed and designed properly. Over the long-term, I am concerned that a limited housing supply will drive up housing prices and decrease affordable/moderate-income living options, especially in neighborhoods closer to downtown. By including options for 3F and 4F-dwellings, higher density can be achieved gradually, without compromising the overall character of the neighborhoods.

Specifically, 3 & 4-family dwellings should be grouped separate from other higher-density Multi-family units, and 3&4-family dwellings should be granted greater permissions in RN-1,2, and 3 Neighborhoods, but with some restrictions on design and location. This could be achieved by grouping 2,3,4-family dwellings together.

Similar to the restrictions in 4.3 Dimensional Standards, C, about multi-family dwellings in the RN-4 District, 3 and 4-family dwellings should be granted similar permissions in RN-1,2,3 if they are on corner lots, adjacent to higher-density uses, with height and parking restrictions.

3. PAGE 1-3, Pending Application

Can you remove the words "was deemed complete by the City". There is a significant investment of time and due diligence made on a property before an application.

Page 5-4, Table 5-2
Commercial Site Design requires all surface parking to be on side or rear unless in CH2 or CR2. Front door parking is a highly desirable feature for most commercial properties. Front door parking should be allowed in C G.

Table 9-1 Use Matrix
For the sake of completeness please add . . .

Add "Heavy Retail, Rental, and Service"
Add "Concrete Batch Plant"
Add "Cement Plant" which is quite different from the Concrete Batch Plant above
Add "Call Center"
Add "Truck Stop and Refueling Facility"
Add "Truck Terminal"
Add "Construction Office with Outside Storage"
Add "Landscaper and Lawn Mowing Office with outside Storage"

Page 10-1: Please add to Site Development Standards requirements for eighteen wheel vehicles and semi trucks in regards to building access and turnarounds.

Please add requirements for loading docks and drive in doors.

Kub Public Utility Requirements

Attached is a draft Section 10.6 PUBLIC UTILITY REQUIREMENTS that KUB would like to be added to the draft Zoning Ordinance document.
Provided MPC and City of Knoxville are agreeable to including this new section, we believe that the following sentence in sections 4.5.A, 5.8.A, 6.4.A, 7.1.D.1, 7.2.D.1, and 7.3.D.1 should be edited as shown.

"See Article 10 for additional on-site development standards and requirements, such as exterior lighting, accessory structures and uses, permitted encroachments, and public utility requirements."

First Draft Of Zoning Code

Dear City Council members:

On behalf of the League of Women Voters of Knoxville/Knox County (LWVKKC), we are writing regarding the first draft of Knoxville's new zoning code. We applaud its bold vision: The new code will enable more density, more diverse and affordable housing, and more alternatives to car-based living.

That said, we are concerned that the draft zoning code curbs opportunities for people to have input on land use decisions that affect them. Four key examples follow, with suggestions for a more inclusive, consultative approach.

Permitted modifications. In Article 10.3 of the draft code, a number of uses and structures additional to the principal structure are described - notably, accessory structures, accessory dwelling units (ADUs), and detached garages. For these additional structures, only building permits and other customary permits would be needed if the requirements in the draft code were met. Unfortunately, those requirements do little to protect abutting property owners.

Per the draft code, ADUs and other accessory structures could be up to 18 feet tall and would require setbacks of only 5 feet from the side and rear lot lines (or no setbacks, in the case of detached garages). In the draft code, no notice to the abutting property owner is required.

An abutting property owner should have prior notice and opportunity to appeal if an accessory structure, ADU, or detached garage is to be located partly within the otherwise-required setback specified in Article 4.3.

Permitted encroachments. Article 10.4 lists several types of permissible encroachments into otherwise-required setbacks: for example, balconies, decks, bay windows, stoops, and unenclosed porches. The maximum encroachment is specified for each type.

It appears that a permitted encroachment may enable other additions along the same side. A stoop, for example, could become the basis for enlarging that whole side of the structure into the setback. (See diagram accompanying Article 16.4; see also pp. 51-52 of

If a permitted encroachment can enable additional encroachment, it renders meaningless the term 'required setback,' and it violates the justifiable expectations of the abutting property owner. At a minimum, that property owner should have prior notice and an opportunity to appeal if additional encroachment is proposed.

Administrative modifications. According to Article 15.4, the Zoning Administrator could, upon a property owner's request, unilaterally approve 'a 10% or less modification to any zoning district dimensional standard in this Code' (p. 15-7). The approval standards listed in the draft code mainly concern the property's characteristics and its owner's needs but also refer to the public health, safety, and welfare (p. 15-8).

Members of the public would have no notice of the requested administrative modification and no opportunity for input prior to the Zoning Administrator's decision. Property owners directly affected by the decision could appeal it, but they would have to file for an appeal within 30 days of the decision. How would they learn about the decision in time to file? That is not clear in the draft code.

The Zoning Administrator should send notice of a request for an administrative modification to abutting and adjacent property owners, allowing them 10 business days to comment before the decision is made. They also should be advised of the decision and their right to appeal, subject to a 30-day deadline.

Planned developments. Section 6 of Article 15 introduces a concept relatively new to Knoxville. As described in the draft code, a planned development (PD) is meant to encourage flexibility and creativity in land development and new structures. PDs would have a special approval process that might exempt them from some regulations while establishing other requirements. Per Article 15.6, PDs would be possible in all zoning districts.

The PD process has three major steps: a concept plan followed by a preliminary plan and then a final plan. The preliminary plan is the crux of the process. The preliminary plan is reviewed by MPC, which sends it with their recommendation to City Council for their approval or denial. If the final plan is in 'substantial compliance' with the approved preliminary plan, MPC staff will recommend approval to MPC, which will then review the plan and approve or deny it.

The same process would be used regardless of the type of zoning district. The sole specified opportunity for public input on a PD is at the preliminary plan stage.

Presumably, planned developments are big deals with good or bad ripple effects. As such, neighborhood associations, business associations, potentially affected property owners, and other members of the public should get notice of the proposed project early in the process, as soon as a concept plan has been developed. Their opportunity for comment should not be limited to the preliminary plan stage. They also should get notice of the staff review for 'substantial compliance' prior to MPC's review and approval of the final plan.

The League of Women Voters has a long tradition of advocating for two twin pillars of democracy: a citizen's right (a) to know, and (b) to participate in government decision-making. As you consider the draft code, please keep in mind the need for adequate public information and consultation on land use decisions, as well as the right to appeal when governmental decisions directly affect a property owner.

Thank you for your service to Knoxville.

Mary English
Land Use and Environment Chair, LWVKKC

Linda Maccabe
President, LWVKKC

Community Forum - Response To Recode Knoxville, Draft 1, 5-10-18

Community Forum is an organization with representatives from many City of Knoxville and Knox County neighborhoods. We frequently advocate on issues that affect the character and integrity of neighborhoods.

Attached is Community Forum's initial Response to the first draft of Recode Knoxville. (View Draft 1 Response) The Response includes material on thirteen topics, including a Supplemental Topic on Manufactured Homes which appears at the end of the Response. Also included is a separate list of all of our Issues Presented for the thirteen topics we are addressing in this Response. (View issues list)

Many of the issues identified impact the City's low density neighborhoods.

We anticipate submitting additional comments as we continue our review of this draft, and additional Recode drafts, and as we review the comments of others. We wish to make clear that we support the Recode Knoxville project. Our objective is to work with others to improve the proposed ordinance.

We would be happy to discuss the issues presented in this Response at any time and to respond to any questions you might have about our Response.

Noise Light Pollution

I understood this update was to correct the vague codes including noise and light pollution. Light and noise are both measurable today and many cities have standards based on zoning. The new codes has exempted streetlights and sports fields which is moving in the wrongs direction. Streetlights are for lighting the streets, not bedrooms or inside restaurants. New cutoff lighting is being used by many new developments, but their effects are ruined by streetlights and now sports fields.

Landscaping Requirements

Parking lots 5,000 s/f and above should have perimeter landscaping requirements and lots 10,000 - 20,000 should also have interior landscaping requirements.

Landscaping Of Parking Lots

The benefits of trees and landscaping are well known. A few of these assets include beautification of public spaces, reduced stormwater runoff, reduction of air pollution, and.cooler ambient temperatures and shade - both of which enhance walkability,

The current parking ordinance allows for reduced or no perimeter or interior landscaping for lots smaller than 20,000 sf. All lots larger than 5,000 sf should be required to have some perimeter landscaping. Lots between 10,000 and 20,000 sf should be required to have graduated interior landscaping (smaller and/or fewer islands), depending on size of the lot.

Lots larger than 20,000 sf should have a landscaping break every 10 spaces rather than every 15 spaces.

Recode Suggestions

I looked over the draft, and have the following suggestions:

1. Define “Blank Wall” There are several great buildings with blank walls, that have designed texture and material patterns, etc., but no windows.
2. Define if an alley or highway (i.e. other than roadway) is a ROW. This has to do with the portion of the code that indicates if a façade is visible from a ROW, then ……
3. Define how far such a ROW view would be. Example, if I can view a building from a higher grade 5 blocks away, while I am in an alley, then is that “visible from ROW”?
4. In DK-H district, set a minimum first floor to second floor dimension. Traditional buildings ranged in 18’ to 20’ +/-
5. If a building is on a sloped street, then does the ground level regulations apply to the entire area of the sloped street, or only the very bottom portion of it?

I will review in more detail in the next few days and will share anything else that I can think of.

New Knoxville Zoning

Has there been any dialogue with Knox County officials about adopting a unified zoning ordinance? This would greatly simplify development document preparation within both Knoxville and Knox County and could still be administered separately as they are now. Also, has there been any talk of expanding the MPC to be a one-stop-shop for development submittals, with the particulars still farmed out to their respective county or city authorities? One of the things we have noticed as design professionals is that the Knox County ordinance generally does not 1) have enough districts, 2) is still written assuming a mostly rural county and 3) is just enough different from the city to be confusing. We have noticed that the City's ordinance 1) seems to assume 1950s and 1960s approaches to development in terms of parking, 2) has too many districts, 3) is not applied uniformly and 4) is not flexible enough to encourage the kind of mixed use and higher density development which would be more environmentally sustainable. Thanks!


Concern is that SW-1 is not listed under the general list of residential. SW-1 is residential (low density). Should It fall under or with the EN, RN, list?


I respectfully disagree that existing noise ordinances are sufficient to address the needs of mixed use development, and I strongly believe that you must include certain noise issues as part of your conversation.

I am writing to you after contacting at least 20 others, from codes enforcement to the police department to the mayor’s office to every city council candidate. The noise ordinances as they are written have an exemption for HVAC units. The Tennessee Theater runs theirs at all hours of the day and night at a volume that is twice as loud as a construction site with heavy machinery running (I have video with decibel readings to show this.) The volume is at a threshold identified in federal standards as causing hearing damage, and yet it is allowed to run at any time of day for any amount of time. This would not be allowed in New York City or in other places I checked.

I needed to get a hearing test due to tinnitus and headaches caused by this noise, and the only way to sleep is to use earplugs and a sound machine at the same time (plus a vibrating alarm clock so I don’t oversleep.) After a few days of earplugs, my ear canals will be raw and near-bleeding. I have invested $3k on sound blocking shutters and will still have to invest another $15k in acoustic retrofitting with no guarantees. I have impact statements from numerous neighbors regarding their own stress levels/health, their inability to use expensive balcony retrofits ordered at purchase, and their need to make expensive architectural changes to their windows.

I’ve lived in urban environments for over 20 years, including large cities. I have many nice things to saying about moving to Knoxville, but I cannot recommend living downtown when people ask because of a general failure to control noise and light pollution here. Knoxville needs to take these seriously in mixed use development if it wants to be successful. My neighbors and I would be happy to discuss these issues with you, and other challenges that have arisen in our building, which is part residential and part commercial.

I realize my email is quite long, and I appreciate your time in reading it.


Is there anything in the new planning regarding noise in residential districts? I don't believe current ordinances are adequate.
Staff Reply:
It is typically not within the purview of zoning ordinances to address noise, as this issue is usually handled through a separate noise ordinance. This is the case in Knoxville and you may want to contact City staff and your City Council member to advocate for enhancements to the City's noise ordinance. The draft zoning ordinance does propose a requirement for a landscape buffer between non-residential and residential development, which may help mitigate the impact of noise.

Mixed Use Development In C-h Highway Commercial Zoning District


I have a question related to the C-H Highway Commercial Zones.

As currently drafted, would a mixed-use development with residential multifamily above a commercial ground floor be permitted in a C-H zone? I see in the Use Matrix that "Dwelling - Above the Ground Floor" is permitted in a C-H zone, but I don't understand whether that implies, multifamily, single family, etc.

Thanks for the help!
Staff Reply:
The intent is to permit either a single dwelling or multiple dwellings on the upper floor(s) of a building in the C-H zone. We will clarify this so there is no confusion.

Drive-through Facility

Consider allowing Drive-Through Facilities in C-N as a Permitted (P) or at least Special (S) use. Given that restaurants, financial institutions, and personal service establishments (I'm thinking of dry cleaners) are allowed in C-N there will certainly be instances when a drive through could make sense.

Comments - Draft Zoning Code

I am a commercial / industrial real estate broker. Below are my comments on the DRAFT Code.

PAGE 1-3

Pending Application
Can you remove the words "was deemed complete by the City". There is a significant investment of time and due diligence made on a property before an application.

Page 5-4; Table 5-2

Commercial Site Design requires all surface parking to be on side or rear unless in CH2 or CR2. Front door parking is a highly desirable feature for most commercial properties. Front door parking should be allowed in C G.

Table 9-1 Use Matrix
For the sake of completeness please add . . .
-Add "Heavy Retail, Rental, and Service"
-Add "Concrete Batch Plant"
-Add "Cement Plant" which is quite different from the Concrete Batch Plant above
-Add "Call Center"
-Add "Truck Stop and Refueling Facility"
-Add "Truck Terminal"
-Add "Construction Office with Outside Storage"
-Add "Landscaper and Lawn Mowing Office with outside Storage"

Page 10-1
Please add to Site Development Standards requirements for eighteen wheel vehicles and semi trucks in regards to building access and turnarounds.
Please add requirements for loading docks
Please add requirements for drive in doors

Concern Over Impact To Residential Housing Values...

I live in Sequoyah Hills. There are currently large commercial developments occurring on the north side of Kingston Pike, which I'm fine with. I think they are doing a good job of providing more affordable housing in the area and creating attractive (physically and financially) symbiotic venues for commercial activity. However, there are rumors of a land grab in the works for the south side of Kingston Pike, west of the intersection with Noelton Dr. If these residential areas are zoned for commercial or multi-family housing, I fear (with good reason) the housing values of all the homes in Sequoyah Hills will take a large hit (10% - 30% based on some bank of the envelope calculations). I would strongly oppose any Knoxville politician/administrator that would approve these areas for anything other than single family dwellings.

Sidewalks - School Zones

Thank you for allowing us to actively participate in offering comments and feedback. I live in Fountain City. We are .50 miles from Fountain City Elementary and Gresham Middle School on Grove Drive, which means that we are in what is called "parent responsiblity zone". Our daughter would like very much to walk to school, however the sidewalks stop less than halfway to our home from the schools. The road is narrow with a ditches and many use it as a cutthrough from Rifle Range to Broadway. People drive fast through the stretch were we live and it is dangerous to walk. We walk as a family and it is not a comfortable walk until we get to a sidewalk. There are children living in Grove Park Subdivision who would benefit from a sidewalk as well.

Please consider ensuring there are sidewalks within the parent responsibility zones throughout the city. This would be a blessing for those of us who have students as well as the general community who enjoy walking without fear of launching into a ditch to avoid the oncoming traffic.

Reflecting Roofs

Increasing the Reflectivity of Structures Could Reduce High Temperatures in Cities

I've been wondering whether it is feasible to include within the zoning codes requirements for reflective roofs. It certainly would help with urban heat island effects. See below.

Recent research has shown that cities, which absorb drastically more solar radiation than the countryside, would benefit from coloring dark surfaces with light gray or white materials. For instance, black asphalt reflects only four percent of the sunlight that strikes it, while grassland and white snow can reflect up to 25 and 90 percent, respectively. In New York City, this "urban heat island" effect can increase temperatures 1-3 degrees Celsius warmer relative to rural areas. Research by the National Center for Atmospheric Research found that by raising the reflectivity of a city's roofs from 32 percent to 90 percent, the urban heat island effect would decrease by a third, reducing maximum daytime temperatures by an average of 0.6 degrees C. Additional studies have found that "cool roofs" could reduce temperatures by 1.8 degrees C in other cities. Urban heat islands can also cause nighttime temperatures to remain high, placing stress on vulnerable populations in need of a recovery period from blistering daytime conditions.

For more information see
Yale Environment 360

Noise/dogs/drunken Parties

There seems to be a popular trend to getting dogs and locking them up either in the house for longs hours or in a fenced yard with no care, exercise, or training. Who do I call when I am surrounded by barking dogs almost non-stop while folks are away and many times home leaving them unattended? I have two on one side, one on the other and four behind me-these are put out around 5:30AM and bark for sometime till they calm down and start up again anytime I am in my own back yard garden trying to work or enjoy it. While one set of neighbors has owned and adapted to stop theirs the other two won't respond to pleas or any amount of talking.

And the one with one dog also has drunken parties on the screened in porch right outside my bedroom window along with dog running back and forth underneath it.


I have lived downtown all my adult life and until now everyone understood how to get along and be considerate of close living with neighbors. I do not know who to call and how to get anything done about this.Animal control came and they just lied and begged off and nothing changed.

My quality of life as well as lack of sleep has lead me to almost sell and leave many times but who would buy a house when they come to look at it and hear all this noise!?

Mixed Use (living Above The Store)

Support residential over businesses for live-work or condo ownership, in downtown as well as surrounding areas such as Broadway and Central Avenue, especially including areas around Happy Holler.

Reduce parking requirements in areas well-served by public transit and with bike lanes. Reduce the need for surface parking lots by supporting shared parking areas.

Input And Suggestion For Recode Knoxville

In recent years the continued growth in Knoxville has reduced the distances between commercial and residential areas. This has resulted in unreasonably loud, unusual and unnecessary noise from refuse collection (from dumpsters) in commercial areas that impact residential areas. The attached proposed change seeks to limit this refuse collection to times that will minimize significant impact to families and children while allowing collection in more commercial areas.

If you would have questions about this proposed change or need examples of where and how this will improve the quality of life in Knoxville please contact me.

Proposed Change to Knoxville Tennessee Code of Ordinances
Staff Reply:
The update of the City of Knoxville zoning ordinance will not include revisions to the City's noise ordinance as that is freestanding ordinance. The update to the City zoning code will propose landscape buffers between residential and non-residential development. The proposed landscape buffers will aid in addressing the issue with noise generated by abutting commercial uses.

Progressive Ideals And Recommendations For Recode Knoxville

Mr. Green,
On behalf of the Knox County Democratic Party Progressive Action Committee, we would like to submit the attached comments on ReCode Knoxville.
Please let us know if you or your team members have any questions on our submission.
Thank you,
Progressive Action Committee
Knox County Democratic Party

Progressive Ideals and Recommendations for ReCode Knoxville

? Regarding Zoning Ordinance Update

Will the update include any new sections using form based code?
Staff Reply:
Draft 1 incorporates the existing the form cords for South Waterfront and Cumberland Avenue, but does not propose additional form districts.

Yard Definitions

I seem to remember a graphic that was used in one of the presentations I saw that showed how the city defines the space in a residential yard. The graphic showed the front and back yard as well as side and standoffs etc. I can't seem to find that graphic now. If it is no trouble and you can find it easily, could you send that to me.

Is that going to change in the recode? If so what will the new definitions be?

Chicken Coops

What is going to happen with chicken coop rules. Has anything been decided?
Staff Reply:
The staff recommendation at this time is to leave the standards for chicken coops as they are now. Please let us know if you fell the standards should be revised in any way.

Zoning Lots

Can you clariify: Does a zoning lot only include connecting lots that are within the same zone? Will this apply to commercial and office zones also, not just residential?

Furthermore, the section addressing zoning lots, you mention that the City has an original ward map and a parcel map. Can you clarify what that means?

Racial Equity


I'm concerned about how Black and Latinx stakeholders are engaged in this process. Is engagement equitable at this point? Also, I hope there is some serious social impact consulting seriously measuring along lines of difference pertaining to race, income, ability, etc. Transportation often widens inequity so I expect that to be a topic of public discussion and addressed in the plan as well. Thus far, I see buzz words about being green but nothing about social impact and explicitly measuring perhaps unintended negative consequences to what we're doing here.

Thank you for your consideration,

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