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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Recreational Vehicles

I originally submitted this comment on 5/9, but never received a confirmation e-mail and it is not showing up on the website so I'll try again. 

My comment is in regard to trailers/RV's. The current code, Article V, Section 8 C, states that:

"On each lot, a total of two (2) (one (1) from any two (2) of the subsections listed below) of the following vehicles may be parked or stored per household living on the premises, and said trailer, or recreational vehicle, shall not exceed forty-five (45) feet in length or nine (9) feet in width; and further provided that said trailer, or recreational vehicle, shall not be parked or stored for more than forty-eight (48) hours unless it is located behind the front yard building line:

1.Recreational vehicle.

2.Hauling trailer.

3.Boat trailer."
In the proposed code 11.12 B

"Recreational vehicles must be located within the interior side yard behind the front building line or in the rear yard. If stored in the interior side or rear yard, the recreational vehicle must be located at least ten feet from any lot line and screened from view from any public right-of-way by a solid fence or wall. If the recreational vehicle is screened by an existing structure or landscape so that it is not visible from the public right-of-way, it is considered to meet these requirements. Temporary storage tents and tarps for recreational vehicles are not considered screening and do not meet these requirements."

I have a few concerns about the new code:

1. There appears to be no limit to the number, or size, of RV permitted, as long as it/they are properly screened from the public ROW. 

2. What about trailers that do not meet the Recode definition of a RV? Cargo trailers, utility trailers, etc.

3. Why is parking behind the front building line no longer considered adequate, the new screening requirements seem excessively restrictive?

Part Deux:

I agree that RV's should be located in the interior side yard behind the front building line or rear yard, but why ten feet from a lot line? A shed can be built five feet from the lot line, but a boat has to be ten feet from it? Why the ten feet requirement?

The screening requirement is overly restrictive for the entire city. There are many lots in the city that due to many factors (lot size, topography, access, etc.) it is impossible to locate the RV somewhere that is screened from view from a right of way. To comply with the new zoning code many property owners would have to pay to store their RV somewhere else, leave it as is and risk fines, or move somewhere that does not have such restrictions. The screening requirement should be removed from Recode and be left up to HOA's and the like.

Drive through most any neighborhood in Knoxville and you will see homes with boats and campers parked next to them, West Hills, Lincoln Park, Parkridge, Marble City, Sequoyah Hills. Across the entire city you will find examples of people storing their RV's on their property without screening. 99% of those are not any more of an "eyesore" than the cars and trucks in the driveway. A full size Sprinter type van with commercial logos all over is permitted without screening, but a boat is not? There are other examples like cargo and utility trailers that would not fit in the definition of Recreational Vehicle that would also be permitted.

Staff Reply:


Dear Knoxville Planners,

Several people have asked me about RV issues in the proposed changes.  If you have a pop-up camper or other vehicle that fits the RV definition, could you still park it in your personal driveway under the proposed changes?  The people who have asked me (two different households) currently park their RVs in their driveways and have steeply sloped yards that would preclude them from parking them any other place.  

They say that the proposed changes are a solution looking for a problem, that if their RV is not bothering anyone, why should it be prohibited? A screen is pricey, etc.  

Can you help me understand this issue better?

Staff Reply:

We have received a number of comments about the proposed standards for parking of recreational vehicles in residential areas. The standards were drafted by the consultants, likely based on their experiences with other communities. I do know if RV parking is a concern in the City and will ask Peter to chime in on that question. If RV parking is not a problem, staff can propose a revision to the standards to make parking of RV's, boats, etc in residential areas easier.

Small Lots Of Record

Is there no longer a provision for Small Lots of Record in ReCode? If I want to build on a nonconforming lot (i.e. RN-4 with <50' lot width) would I need to seek a variance?

Staff Reply:

Yes. You would need to seek a variance.

Single Wide Manufactured Homes Taxation

Does Camiros realize that Tennessee TAXES ALL mobile homes, even those on LEASED land (such as in mobile home parks), as IF they were single family dwellings on permanent foundations? They are NOT licensed.

That might help. I would THINK that zoning regs and codes would need to conform seamlessly with taxing regs, especially property taxing regs.

Staff Reply:

Single Wide Manufactured Homes

On page 9-10, it says:

" H.  Dwelling - Manufactured Home 

Multi-sectional manufactured homes may be used as single-family detached dwellings provided the following development criteria are met:..."

What about SINGLE wide manufactured homes? Are they addressed somewhere else?

Staff Reply:

Manufactured Homes

They apparently deleted completely the non-conforming paragraphs about manufactured homes in Article 17, but they left in THIS:

'On Page 9-10, it refers to Nonconforming Manufactured homes being found in Article 16, when it was in Article 17.

"... 3. Nonconforming Manufactured Homes See Article 16 for regulations regarding nonconforming manufactured homes, including single-wide manufactured homes. ..." '


PLEASE DELETE number 3 on page 9-10.

They also left in the "skirting" type required on manufactured homes.... EVEN THOUGH IT DOES NOT APPLY DOWN HERE. (Page 9-10, 2b)

Okaaaaaay! But trust me, mobile home communities are REQUIRING many owners to replace their skirting this year! Good luck fielding all of THOSE requests to be allowed to replace vinyl skirting with just vinyl skirting again instead! Bwahahaha

Staff Reply:

Article 6

Hi, I’m interested in reading the following article: 

    Increase rear setback for industrial uses when adjacent to residential zones to 50
But it shows the page as not found on the website. Do you know how I might be able to read it?

Staff Reply:

Hi, Erin. I'm not sure why you're having trouble opening that link. Try opening it here. If you still have trouble, please let us know. 

Recode Knoxville - Did Not Make Change!

Single wide mobile homes are also still allowed down here on some land. Please take that into consideration.

Staff Reply:

Typo On This Page

There is at typo on the submission page, "Use can this form to submit a comment or question for the project staff or send an email directly to"

Staff Reply:

Adu's Are Not Evil.

Members Recode Team,

I want to encourage those who have worked so hard on this and I hope that your work is not in vain. Please no not let a small but loud section of the population bring down progress. People who have watched this grueling process know that pushing it down the road or starting from scratch won't help. I just hope that there is flexibility in this code to evolve and adapt to a growing city and that we are not subject to the groanings of a few small minded citizens.

I've noticed all of this fuss over ADU's and I am tired of it. I am appalled at the close-minded thinking that an extra unit will have a catastrophic affect on the community. In fact, it is that very thinking that will hold Knoxville back as we try to grow. 

Does it not seem strange that in a time where we have the means to support safe and clean density, we are scared of a density level that our city was built? Is it also not telling that the most beautiful and well-liked areas of Knoxville are the most dense? 

DENSITY IS GOOD. As a designer who has studied architecture and urban planning in depth and in many cities, it irks me that people who have no bases of study for which to make an educated decision are restricting something that will be good for communities and home owners. 

Please, do not let misguided fear hurt this city's future. 

As for the current draft, I believe it is in the best interest of the city to change the following: 

10.3.B.1 : "When there are practical difficulties involved in carrying out the provisions of the building codes, the building official may grant modifications for individual cases." This was omitted and although I don't see a reason why someone might need to diverge from the building code, there should always be room for special circumstances.. Why omit this?

10.3.B.2 : This entire point should be omitted. 1. An owner of a duplex may have a good reason to add an ADU and this should not be restricted. 2. My goodness, "Must be owner occupied" What good does that do to the community? Are there not countless individuals in this city who survive off income from rentals? Much of this city's revitalization has been a result of enterprising folks who flipped houses not for themselves but for others. Knoxville owes the quality of it's urban neighborhoods to these folks. Who's right is it to base the urban growth of a city off of whether a property is owner occupied? Please don't incapacitate future growth by restricting things like this. 

10.3.B.4 : Lot size restrictions. There are countless historic lots of record in Knoxville that are smaller than 5,000 sf but have a small house on them that would support an ADU plus be true to historic and appropriate for future density. 

10.3.B.8 : Again, we should not be controlling the square footage of a dwelling unit. What if it has a basement or upstairs that are appropriately scaled to the main house? This is a foolish blanket statement that does not take into consideration the high number of smaller (historical) lots in the city. 

If ADU's are an issue of different parts of the city wanting different things, I see no issue with dividing the regulation into districts, if the western population is afraid of density, let them keep their malls, and parking lots and live with the raising obesity, depression, and un-satisfaction that has been proven to come from being disconnected from a tight community. As for the neighborhoods around downtown, please don't restrict their growth. 

Staff Reply:

May 14, City Council Meeting For Rezoning Article 1

Please advise if recode Knoxville, Article 1 will be the only article discussed on May 14, 2019?  Will all 18 Rezone Articles be discussed at a later date for review of public opinion?  Please forward the dates and Articles to be discussed for each future meeting for the 2019 Rezone Articles? Thank you for your prompt response!

Staff Reply:

All articles will be discussed at the May 14 meeting.

Landscape Bond

The following should be added to Article 12. LANDSCAPE

In order to ensure correct installation and maintenance of landscaping, a landscape bond will be required.

No certificate of occupancy will be approved before the developer or owner has posted a landscape maintenance bond guaranteeing all landscaping materials and work for a period of two years after approval or acceptance thereof by the City in a sum established by the Knoxville-Knox County Planning Commission. The bond will be in the amount of 110% of the estimated cost of replacing and maintaining the landscaping required by these specifications, unless otherwise specified by the Knoxville-Knox County Planning Commission. 

A. Inspections

1. Installation
The developer or owner will be allowed six (6) months after a certificate of occupancy has been issued to install landscaping material according to the approved plan. This will enable planting to occur during optimal weather conditions and to ensure the availability of the approved materials. At the end of six months, the Zoning Administrator will inspect all required landscaping and certify that it has been properly installed and is in good health. If corrections are to be made the Zoning Administrator will notify the owner or developer. All unhealthy, defective or dead plant material will be replaced within three (3) months, at the end of which the Zoning Administrator will again inspect the landscaping. The bond shall be called if the required landscaping has not been installed or corrected by the end of this period, and the funds shall be applied to complete the landscaping work.

2. Maintenance 
Two years after a certificate of occupancy has been issued the Zoning Administrator will inspect all required landscaping and certify that it has been properly maintained. If no maintenance is required, the City will release the landscape bond. If corrections are to be made, the Zoning Administrator will notify the owner or developer and the bond company of any corrections. All unhealthy, defective or dead plant material shall be replaced within three (3) months. The Zoning Administrator will conduct a final inspection and if no further maintenance is required, the City will release the landscape bond. If deficiencies in the landscaping still exist, the bond shall be called and the funds shall be applied to complete the landscaping work.

Scenic Knoxville
Trees Knoxville
The City of Knoxville Tree Board

Staff Reply:


STOP this stupidity! Leave the single family neighborhoods alone! The students/temporary residents have much of the urban area of Knoxville so leave working families alone in the neighborhoods they have made stable, safe, thriving, productive areas! Don't run the people, that have worked hard to make their communities better, out! We purchased in single-family, leave it the freak alone. Transient and multi-family residents usually do not have the same desire to maintain and improve upon and invest in (emotionally and financially) their neighborhoods. The area I am in is the Belle Morris area. We all know this BS wouldn't fly in a more affluent area such as Sequoya Hills and Farragut! So STOP messing with the more urban areas! These urban areas are now the safest, most stable, and valuable in modern history! How can you change the zoning of people's homes?!!. How is that fair and equitable?? They have purchased and invested in single-family areas and it is very unfair to change the nature of their neighborhoods by fundamentally changing the environment by re-zoning it ! I am from the Atlanta area where unbridled growth has ruined many established (safe, solid, stable) neighborhoods. Smart growth and planning is needed but the changes noted in Re-Code are not that. For goodness sakes, LISTEN TO THE PEOPLE! DO NOT RE-ZONE SINGLE FAMILY URBAN AREAS! Knoxville used to be a GREAT and AWESOME place to live. However, our government seems to think bigger, better, faster is better and we all know it isn't. Monkeying around with zoning by changing single family areas to multi family or multi residential will be the death-nail of this area. HOMEOWNERS are the key. The students don't stay, renters usually move on,. Market-square, downtown will slowly die. The revitalization of the Central Corridor will slow and eventually stop. Past is prologue. 20 years ago this area was the pits. Abandoned homes, high crime, etc. It's stabilized and thriving. Crime and traffic will increase and good quality caring residents will flee. Not being smart about growth and fundamentally changing the Knoxville Downtown urban neighborhoods will drive this place into the ground and drive good quality citizens to the nether regions. Stop it!

Staff Reply:

Thank you for your email. The Belle Morris neighborhood is proposed as RN-2 on the draft updated zoning maps. This is a single family residential designation that permits single-family residential development on lots with a minimum size of 5,000 square feet and also permits duplexes as a special use. Review and approval of duplexes by the Planning Commission would be required at a public hearing and neighbors would be notified of the hearing. The proposed zoning is equivalent to the current R-1A zoning of much of the neighborhood. Planning staff worked with the neighborhood association to preserve the single-family designation and to identify locations for small scale multi-family development on Cecil and Brown Avenues near the industrial area. Also, properties currently designated as multi-family and/or on which multi-family development is currently located were designated multi-family. The multi-family designations represent a small portion of the neighborhood. We appreciate the effort expended by the neighborhood association in working with Planning staff to develop the draft zoning map for the Belle Morris neighborhood.

Generally, the Recode process has been responsive to much of the public's concerns.  However, there are enough changes, and enough items not changed that we thought would be, to warrant a slight delay in the Council's final decision process.  Government is held to a high standard.  It must not only be fair; it must also appear to be fair.  Please consider holding a public work session May 14th with the understanding that the First and Second Readings will be completed before the end of June.   This alleviates concern over the brevity of review time provided between the final document and City Council action while guaranteeing that it will indeed be finished in the near future.

Please consider these few remaining questions/comments I have:

1.     Clarify how building grade is determined when measuring building height as described in 2.4.E.1:    is it finished grade or original grade (I have seen grades intentionally raised)?  To measure height do you take the average of the grade along the base of the building's front or at various points along the buildings front?  Note that grade is defined for signs in the Sign Chapter.  Why not for development?

2.    Article 8.9.B has removed hillside overlay protection for nonresidential, stating that this complies with vesting provisions.  However, I cannot find a reason when reviewing Article 15.3.  And why have maximum land disturbance regulations been removed?

3.     An application for a wireless tower in Burlington was successfully defeated because it was required to have a public hearing and through that public hearing process Town Hall East Neighborhood Assoc. was notified.  Research discovered the tower was not necessary to provide coverage; it would have only improved existing coverage.  Town Hall East opposed the application and worked closely with the provider, resulting in a withdrawn application.  Draft regulations in Article 9.3.FF remove the public hearing process, allowing a tower to be permitted with no negotiation.  This is not good. 

4.    Effective public notice is the foundation of our public involvement process. Add a method to notice Zoning Code Interpretations in Table 15.1   How the Zoning Code is interpreted is important and should be shared with the public 16.9.      Include the registered neighborhood association in mailed notice referenced in 15.2.
5.    Require 15.2.D posted notice (aka signs) to be unobstructed, clearly visible from all traffic lanes and individually fronting each adjacent right of way.  There has been past documentation of signs posted behind telephone poles or mixed in with campaign signs.

6.    The Variance standards 16.3 have been reworded to fully support the premise that variances should be the exception.  Please add the additional criteria that the Applicant did not cause the reason a variance is now deemed necessary.    

Thank you very much for your patience and continued concern for the public process while also balancing the need to get things done.

Staff Reply:

Inequitable Distribution Of Recode Benefits

ReCode has fallen short of its promise. Parkridge / Park City and all of East Knoxville should be talking about the inequitable distribution of benefits under ReCode Map draft 4 (final version before vote).

As one example, I asked repeatedly for "open space" or similar land use designation on Chestnut Ridge / Adams Ave to maintain a forested buffer for Parkridge from Interstate 40 (a best practice in zoning, as "freeway" and "residences" are incompatible land uses and a buffer should separate them). While Parkridge did not get any such open space / forested buffer, multiple parcels along Interstate 140 (Pellissippi Parkway) in West Knoxville did.

As another example, churches in West Knoxville got zoned "Ag" while not a single church in East Knoxville was zoned "Ag." Not even the historic "Underground Railroad" site on Fuller Ave (which I specifically asked be protected with "Open Space" zoning), or Tabernacle Baptist Church on MLK that actually has a community garden. That means if a congregation "goes away" in West Knoxville, neighbors are left with Ag / Open Space. If a church "goes away" in East Knoxville, it's a free-for-all for private developers. 

Why the disparity?

Staff Reply:

Tree Mitigation Bank

We think it's important that Knoxville's zoning code includes a provision for a Tree Mitigation Bank. This Bank would garner additional funds for the COK to use for landscaping on public property. It would also level the playing field by insuring that all developers were responsible for the same costs for equivalent development. We propose the following amendment be added to Article 12. LANDSCAPE


The Tree Mitigation Bank is established as an alternative to maintaining or planting required trees and landscaping as specified in the Tree Protection Ordinance and in Article 12 of the zoning ordinance. Costs will accrue to the applicant to the degree it is not possible to maintain, replace or plant required trees and landscaping. The Tree Mitigation Bank provides a method of compliance in circumstances when the on-site maintenance and planting of required trees and landscaping is not possible due to site constraints, or for the mitigation of violations.

Funds paid into the Tree Mitigation Bank will be used for the sole purpose of planting trees and landscaping on public grounds and rights-of-way. The City of Knoxville urban forester will administer the account and determine when and where trees and landscaping are to be planted.

A.  When a strict application of the landscaping requirements or the use of an Alternative Landscape Design would require unreasonable compliance, an applicant may request  permission to contribute to the Tree Mitigation Bank instead. Such situations could include water features, topography, lot configurations, utility maintenance zones, or unusual site conditions.

B.  To use the Tree Mitigation Bank, the applicant must submit a Tree Mitigation Bank request that includes a list of landscaping requirements unable to be met and the specific reasons why they cannot be met. The request must be submitted to and approved by the Administrative Review Committee. The Administrative Review Committee will determine the extent to which requirements cannot be met and contributions to the Tree Mitigation Bank can be substituted.

C.  Final permission to contribute to the Tree Mitigation Bank requires the Zoning Administrator's approval concurrent with the application process for the development.
D.  Required contributions are based on current economics and can be determined by referring to.... on the City of Knoxville website.

Prepared by:
Scenic Knoxville
Trees Knoxville
The City of Knoxville Tree Board
The Knoxville Chapter of the American Society of Landscape Architects
Sierra Club, Harvey Broome Group

Also endorsed by:
Town Hall East
Forest Heights Neighborhood Association
Community Forum
The Bearden Village Council
The Riverside 1 Condos
Historic Fourth and Gill Neighborhood Organization
Kingston Pike Sequoyah Hills Neighborhood Association
Alice Bell Spring Hill Neighborhood Association
League of Women Voters of Knoxville and Knox County
RiverHill Gateway Neighborhood Association

Staff Reply:

Recode Knoxville

To whom it may concern: 

I live in the Beau Monde subdivision within the greater confines of the Northshore Town Center (NTC). I have recently learned that it is proposed under the Recode Knoxville plan that the property just south of our subdivision boundary is to be changed, as part of the plan, to C-R-2 from its current designation of TC-1. While the impact of such a change may not seem to be significant, there are substantive changes that would negatively impact the "transition" areas currently enjoyed that buffer the heavy commercial areas that Publix, Target, the credit union building and a medical facility currently under construction from the less intense use of a residential area. Specifically, I have concerns that more intense commercial facilities could be built much closer to residences than under the current zoning designation and that such facilities could be built to a maximum height of 65 feet. Such development would make a mockery of the the transition area and would be deleterious to the current residents and potentially negatively impact property values.
We currently enjoy the environment of NTC's mixed use, new urbanism development and would hope that it continues to develop in a manner sympathetic to it's master plan. We would be very disappointed in our planning and political leaders if the zoning changes up for consideration resulted in new urbanism replicating the mistakes of old urbanism.
Thank you for you consideration of my concerns and for all that you do to make Knoxville such a great place to live. 

Staff Reply:

Map 4

Hello, I have been following the recode very closely, workshop and stakeholder meeting. This draft 4 of the map is very concerning, it is alllllll over the place. Lots in our neighborhood that are duplexes or converter duplexes have been rezoned as multi family R3 and R4, duplexes are in the R2 zoning. I was told part of the reason that recode was needed was to make what is on the ground match the maps, but there are lots of apartment building along Kingston Pk, they are all zoned as R1. The block across the street from me has been rezoned to R4, most of the block is taken up by a school, should it not be zoned for school (institutional) like all other schools? I checked the zoning for churches, its is all over the place from R1, R2, O, OS, Agr, which is it? Then part of Caswell Park was to be rezoned as R4, sense when did park land become up for grabs for multi family housing, if so there is alot of park land on Cherokee Blvd. I dont think this recode is now where near ready to be voted on. I have heard some say that it came be amended after its past, thats like building a house and the builder says that he will go back and fix all the structural issues AFTER the house is completed....totally asinine!

Staff Reply:

Revision Five

Good Afternoon,

We've looked through the recent revision. The following comments are respectfully submitted for your consideration.

Article 2 should include a definition of the term "mixed use".

Article 2 should include a definition of the term "interlock" as used in table 11-6.

Article 6.3 - Industrial zone setbacks: Has the rear setback exemption for sites with railroads been eliminated? Many forms of industrial buildings need to have direct access to rail service.

Article 11.1 - Off street parking applicability is rather confusing.

Article 17: Nonconformities: These transition rules are difficult to understand. I suspect consistent enforcement will be onerous.

Staff Reply:

Recode Knoxville Process

I object to the use of the ReCode process by city employees to attempt to rezone city-owned land without due process. I support Marshall Stair's proposal to postpone a vote on this. The public has not had adequate time between the last update and the vote.

Staff Reply:

Recode Knoxville Process

I object to the use of the ReCode process by city employees to attempt to rezone city-owned land without following the proper process and ensuring transparency. I support Councilman Marshall Stair's proposal to postpone a vote on this. In addition, the public has not had adequate time to submit feedback between the last update and the scheduled vote.

Staff Reply:

Community Forum: Re: Recode Draft 5--- 5-10-19

Community Forum has previously submitted comprehensive Responses to Recode Drafts 1-4.  Community Forum is currently preparing comments on Draft 5. 

However, the comments will not be submitted by the May 10, 2019, deadline.&nbsp; Draft 5 was made available to the public, on line, on May 1, 2019.&nbsp; It is impossible to provide meaningful comments in 10 days to over 400 pages of law, as well as to the new maps which only more recently became available.

As was stated in Community Forum&rsquo;s letter to City Council on April 29, 2019, we urge that consideration of Recode at the Special Meeting, called for May 14, 2019, be postponed to allow more time for City Council and the public to analyze and offer comments to Draft 5 and the latest maps.

Community Forum requests that there be future City Council workshops to discuss Draft 5, with its many changes made since Draft 4 came out in late December 2018.

It should be up to City Council to determine the future timetable for workshops, the date of a Special Meeting to consider Recode, and any amendments that may be offered to Draft 5.


Larry Silverstein, Chairperson, Community Forum

Staff Reply:


Several of the drafts I have looked at point to my property as the property to my left, a much small property. My home is 5212 Holston Dr Knoxville,Tn 37914, which is 8.78 acres, house/barn etc. This needs to be corrected. Thank you.

Staff Reply:

Proposed Zoning Map Error

Becky Wade, in a memo to the Knoxville City Council last night (May 7, 2019), stated that the erroneous designation regarding the East 5th/Myrtle Street land parcels would be restored to the original "Open Space" designation by this morning. I checked the website and cannot see that this was handled as stated. Can you please provide an update as to the restoration of the correct zoning designation for these parcels or show me the proper place to find that the correction has been made?

Staff Reply:

Recode - Rn-5 Residential Care Facility

Just wanted to be up-front with you that I'm not sure how I feel about the change allowing RN-5 to allow Residential Care facilities, even if it's a special use. Can you elaborate on why this change was made? The unfortunate reality is that much of North Knoxville had larger parcels redeveloped into Multi-Family developments in the 60's-70's (including right across from my house) and my fear is that given the profitability of Residential Care facilities, that this change could create incentive for owners to redevelop these buildings/complexes into Residential Care. 

My original hope was the opposite, that the RN-5 in allowing townhouse-type developments, that these properties would become less suburban and more urban. If we have to keep Residential Care facilities as a permitted special use, could we down-zone many of these apartment buildings to RN-4? My specific concern is 1722 Coker Ave, however that concern extends to all these property types in the middle of predominantly single-family neighborhoods.

Staff Reply:

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