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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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'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:


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:

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:

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 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:

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