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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Climate Knoxville Recode Knoxville Comments

Climate Knoxville submits comments and background information on the current draft of Recode Knoxville.Louise GorenfloClimate Knoxville
Staff Reply:

Recode Knoxville

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

Park City Preservation Alliance

The Park City Preservation Alliance (PCPA) is a not-for-profit organization dedicated to the preservation of the places, stories, history, and culture of the people of, in, and near Historic Park City, Tennessee.The PCPA Board of Directors have agreed on the following recommendations for ReCode:1. OS-1 should be retained as an option to conserve historic, archaeological, and cultural values of open space, rather than merged into the new OS that does not reflect these important land uses.2. The Historic Zoning Commission should be granted authority to allow variances for rehabilitation and habitation of documented historic accessory structures that may be non-conforming under new zoning ordinances.3. The Historic Zoning Commission should be granted authority to allow variances to permit re-building of the foundations of lost, documented historic accessory structures to allow future, code compliant construction of habitable accessory dwelling units.Sincerely,Park City Preservation Alliance Board of DirectorsPresident, Greta SchmoyerVice President, James WaldrupTreasurer, Ed StricklandSecretary, Tanner Jessel
Staff Reply:

Recode Comments - Broadway Corridor Task Force

Good EveningThanks again for meeting with Kyle and me a few weeks ago to discuss ReCode and its affect on the Broadway Corridor. As you may have seen, we have been submitting map-related comments over the past few weeks. However as we discussed in our meeting, we compiled a document with all of our general code and map-related comments, and attached that document to this email.If possible, would you mind having someone on your team go through the attached document to make sure each of the comments (specifically, the map related comments) were submitted and/or taken care of? We spent a good amount of time getting all of these comments together and they developed over time so some of our previous comments may need to be updated, and we would hate for some of the comments to be lost (it became hard keeping track of what was submitted, and what was not).Thanks again for all of your hard work in coordinating this effort, and we apologize that we are submitting these comments right up against the deadline! If you have any questions please feel free to reach out to me.Sincerely,Jimmy RyanKyle Anne LangBroadway Corridor Task Force
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 experiences2. 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.Best,Jennifer Roche, JD, RCEGovernmental Affairs DirectorKnoxville Area Association of Realtors609 Weisgarber Road, Knoxville, TN 37919
Staff Reply:

Comments On Public Draft Version 2.0

We have evaluated the current draft and respectfully submit the following comments regarding office development in the City of Knoxville:The document would be easier to navigate if all the office districts were collocated; preferably in the commercial district.Clinics and medical office buildings should be a permitted land use within the OP district.Thanks for the opportunity to comment,
Staff Reply:

Recode - Food Truck Parks

We are the Owners of Central Filling Station - the existing food truck park on N Central. We recently had a chance to review the second draft of the ordinance, specifically the portion regulating "Food Truck Parks" - Article 9.3 (L). As written, there are several provisions in direct conflict with our existing operations and the new requirements are considerably different from MPC's previous draft of an ordinance for a "Mobile Food Unit Park", which guided the development and approval of our project last year.We are concerned not only for our existing business, but also the ability for future "non-conforming" businesses to have a path to compliance. We have attended several of the public meetings about ReCode, so we're up to speed on the process.Is someone from MPC able to meet with us to discuss our concerns?
Staff Reply:

Bring Back R3 And R4

Hi,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:

Please find the attached position letter from AIA East Tennessee. We would appreciate your consideration on these issues.John Sanders, FAIARecode Knoxville Advisory Committee Representative for AIA ETN
Staff Reply:

Recode - Food Truck Parks

To follow up on our meeting two weeks ago, we have attached a revised draft of the ReCODE language concerning Mobile Food Unit Parks. Most of the revisions came from combining the previous MPC draft ordinance and the ReCODE public draft v2.0. We also removed any redundancies and brought the terminology in line with the City's existing MFU Ordinance.The only substantial changes we have suggested are:1.) Removing the min/max lot size requirement from the MPC draft ordinance. The maximum number of MFUs per parcel should sufficiently regulate the density of MFUs and the types of lots that would be viable.2.) Removing the requirement for MFUs to leave the park at the end of each day from the ReCODE draft. The existing MFU ordinance already requires MFUs parked on private property to leave each day, and does not require MFUs to visit a commissary. The only instance where an MFU could legally remain on the private property where it operates would be at a permitted MFU Park, which will have been reviewed, inspected, and permitted by the office of Plans Review and Inspections. There will be a designated operator on site during all hours of operation to address any concerns or complaints. The health, safety, and welfare concerns of each MFU's food service operation are already regulated by the Health Department. We feel very strongly that the ability to offer longer term leases to individual MFUs within a permitted MFU Park is critical to their financial viability. 3.) Adding a requirement for all MFU Parks to provide shore power for all MFUs. We feel like this has been incredibly successful in eliminating any neighborhood concerns about these types of projects becoming a nuisance. Eliminating mobile generators keeps this use much more in line with the other uses permitted in commercial zoning districts and the development cost of providing the power should not be prohibitive. Please review and let us know if you have any questions or comments. Thanks again for taking the time to hear us out.
Staff Reply:

Kcdp Pac Comment Submission On Recode Knoxville Draft 2 Text And Draft 1 Map

On behalf of the Knox County Democratic Party (KCDP) Progressive Action Committee (PAC), we would like to submit the attached comments on ReCode Knoxville Map Draft 1 and ReCode Text Draft 2.Below is the list contributors and/or ratifiers of these comments: Core Drafting & Research Team:Elizabeth RowlandMatt SterlingMoira ConnellyIdea/Feedback Contributors:Michael DavisBryan Hill CharLee HowardRatified Final Draft:Linda Haney - KCDP Vice Chair Allie Cohn - PAC Co-Chair & KCDP Secretary and Executive Committee MemberMichael Davis - PAC Co-Chair & KCDP Executive Committee MemberSylvia Woods - PAC Steering Team Member, KCDP Executive Committee Member & Tennessee Democratic Party Executive Committee Member LaKenya Middlebrook - PAC Steering Team Member Elizabeth Rowland - PAC Steering Team MemberMoira Connelly - PAC Steering Team MemberMatt SterlingLouise SeamsterBryan HillWe'd also like to bring to your attention a Democratic Television (DTV) episode that we did explaining ReCode Knoxville to viewers.Please let us know if you or your team members have any questions on our submission.Thank you, Elizabeth Rowland
Staff Reply:

Draft 2.0 Of Knoxville's Proposed Zoning Code

September 13, 2018Dear City Council Members:We are writing on behalf of the League of Women Voters of Knoxville/Knox County (LWVKKC), an organization with more than 200 members. Our comments address Draft 2.0 of the proposed zoning code, using the League's adopted principles and positions as their basis. We don't address Draft 1 of the zoning map, other than to say that technically it is well-done and easy to use. LWVKKC supports this much-needed zoning code update, with its streamlined reorganization and concise presentation of complex material. The League also supports two key goals implicit in the proposed code: (1) addressing the growing need for affordable housing in Knoxville, and (2) encouraging less reliance on personal vehicles for mobility.Nevertheless, LWVKKC has two significant concerns with the proposed code: (1) Although affordable housing and vibrant, stable neighborhoods are supposedly part of the vision for Knoxville, some measures in the proposed code - unless revised - may work against that vision. (2) In an effort to achieve greater administrative efficiency, short shrift is being given to citizen's right to know about and comment on land use decisions that affect them.Our specific comments are summarized below. Detailed versions of these comments are attached, organized by the articles in which they occur. ______________________________Hillside Protection Overlay. The HP Overlay should apply to all types of districts - residential and non-residential - as it did in the 2011 Hillside and Ridgetop Protection Plan adopted by City Council. Infill Housing Overlay. To foster affordable, compatible housing in older neighborhoods scattered around the city, we should keep the Infill Housing overlay.Accessory Dwelling Units. To add to the stock of affordable housing in Knoxville while minimizing disruption of stable neighborhoods, ADUs should have two restrictions: (1) their use as short-term rentals should be prohibited, and (2) in EN, RN-1, and RN-2 neighborhoods, they should be limited to owner-occupied properties. Required Notice of Public Hearings and Meetings. Required notice of a public hearing/meeting should include information on how to submit written comments.Administrative Modifications. 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. Immediately after the decision is reached, they should be advised of (a) the decision made, and (b) their right to appeal it. Planned Developments. 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. __________________________While still a work in progress, the proposed code is an important step forward. Thank you for all your effort on this monumental task.Sincerely,Linda MaccabePresident, LWVKKCMary EnglishLand Use and Environment Chair, LWVKKC
Staff Reply:

Affordable Housing

Please put back the orange! More, not less, affordable housing is needed. Thank you.
Staff Reply:

Affordable Housing

PUT BACK THE ORANGE. Knoxville needs more multi family housing not less. You are prioritizing higher income folks and not pushing Knoxville to be a city that prioritizes the vast need for affordable housing. I've been to meetings and you are always citing comments from West Hills or Sequoya Hills, or Fountain City and not referring to comments made at the Urban League meetings from Burlington residents from East Knoxville residents and you actively tell them you are not recording their comments despite the fact that a forum or meeting could be their only way to provide a comment. PUT BACK THE ORANGE and stop excluding low income folks' comments.
Staff Reply:

Recode Knoxville - Lighting Ordinance

I'm writing because of your role on the Recode Knoxville Advisory Committee. Have you looked up in the night sky lately and noticed how few stars are visible? Light pollution obscures the natural beauty of our skies and wastes so much energy. Knoxville's initiative to redo the zoning code is the perfect opportunity to create zoning restrictions that position us as a leader in protecting the night skies and saving energy. As we continue to develop the Urban Wilderness, this facet of our zoning code is something we must consider.Will you propose to the Advisory Committee, City leaders, and the City Council that Knoxville's new zoning include a section based on the Pattern Outdoor Lighting Code (POLC), helping Knoxville to lead our region in reducing lighting pollution?Thanks for your time. I look forward to your response!
Staff Reply:

Rezoning

Affordable housing is at crisis point for many people in Knoxville. Homelessness is on the rise in our city due to a lack of affordable housing. "Bring Back the Orange! in our core neighborhoods by utilizing RN-3,4, and 5 zones to allow for a greater range of housing choices in walkable, bus-friendly neighborhoods. Please adopt appropriate zoning & standards to encourage good design, scale, and development in a manner that will protect our neighborhoods while still allowing them to evolve."
Staff Reply:

Recode - Food Truck Parks

To follow up on our meeting two weeks ago, we have attached a revised draft of the ReCODE language concerning Mobile Food Unit Parks. Most of the revisions came from combining the previous MPC draft ordinance and the ReCODE public draft v2.0. We also removed any redundancies and brought the terminology in line with the City's existing MFU Ordinance.The only substantial changes we have suggested are:1.) Removing the min/max lot size requirement from the MPC draft ordinance. The maximum number of MFUs per parcel should sufficiently regulate the density of MFUs and the types of lots that would be viable.2.) Removing the requirement for MFUs to leave the park at the end of each day from the ReCODE draft. The existing MFU ordinance already requires MFUs parked on private property to leave each day, and does not require MFUs to visit a commissary. The only instance where an MFU could legally remain on the private property where it operates would be at a permitted MFU Park, which will have been reviewed, inspected, and permitted by the office of Plans Review and Inspections. There will be a designated operator on site during all hours of operation to address any concerns or complaints. The health, safety, and welfare concerns of each MFU's food service operation are already regulated by the Health Department. We feel very strongly that the ability to offer longer term leases to individual MFUs within a permitted MFU Park is critical to their financial viability. 3.) Adding a requirement for all MFU Parks to provide shore power for all MFUs. We feel like this has been incredibly successful in eliminating any neighborhood concerns about these types of projects becoming a nuisance. Eliminating mobile generators keeps this use much more in line with the other uses permitted in commercial zoning districts and the development cost of providing the power should not be prohibitive. Please review and let us know if you have any questions or comments. Thanks again for taking the time to hear us out.
Staff Reply:

Recode - Food Truck Parks

We recently had a chance to review the second draft of the ordinance, specifically the portion regulating "Food Truck Parks" - Article 9.3 (L). As written, there are several provisions in direct conflict with our existing operations and the new requirements are considerably different from MPC's previous draft of an ordinance for a "Mobile Food Unit Park", which guided the development and approval of our project last year.We are concerned not only for our existing business, but also the ability for future "non-conforming" businesses to have a path to compliance. We have attended several of the public meetings about ReCode, so we're up to speed on the process.
Staff Reply:

C-g-3 District: Maximum Building Height

In Draft 2 of the code, the maximum building height for C-G-3 districts was changed to Unlimited. The Bearden Village Council has discussed this change and is strongly opposed to it. We request that you restore the 85' maximum shown in Draft 1. Virtually all of the commercial corridor through Bearden Village, from Western Plaza to Northshore Drive, is designated as C-G-3 in Draft 1 of the zoning map - a much larger concentration of C-G-3 zoning than anywhere else in the city. We think an 85' maximum building height will adequately accommodate dense development while retaining some of the current character of Bearden. If a taller project with special features comes along, the "planned development" approach described in the draft code remains an option. Mary EnglishPresidentThe Bearden Village Council
Staff Reply:

Re-code Comment

As a Knoxville resident living in a transitional area that is undergoing gentrification, I am very concerned about the future of racial and economic diversity in our neighborhoods. It is absolutely imperative that any zoning changes resulting from the recode process accommodate the need for increased housing density that would be necessary to preserve socioeconomic diversity.
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:

Recode Knoxville "housing"

I feel that a variety of types of housing is necessary to accommodate people, but consideration should be taken in where they are placed. For example, I would not want a duplex or apartment building next to my house.
Staff Reply:

Current Zoning Proposal Violates Of Fcc Ruling Prb-1

The current Knoxville zoning proposal in section 10.3 C.1 and C.2 regarding the regulation by municipal authorities of Amateur Radio antenna height and support structure height is in contravention of the Memorandum Opinion and Order in FCC PRB-1, issued 9/16/85. The legal cite is 101 FCC 2d 952 (1985) and it can be found on the FCC Web page:PRB - 1 (1985) (https://www.fcc.gov/wireless/bureau-divisions/mobility-division/amateur-radio-service/prb-1-1985)To summarize: FCC regulations have the force and effect of federal statutes and are binding on the states as well as agencies of local government, including local zoning authorities. These regulations contain three general requirements: 1) local zoning authorities may not prohibit Amateur Radio communications and 2) local zoning authorities must provide reasonable accommodation for Amateur Radio antenna requests; and 3) local land use regulations affecting Amateur Radio antenna facilities must constitute the minimum practicable regulation to accomplish a legitimate municipal purpose.Limiting an antenna support structure height based on the height of a building where the tower is located is in contravention to PRB-1, as proposed in the Knoxville zoning document.Limiting an Amateur Radio antenna to a specific height above the roof of a building it is installed on is in contravention of PRB-1, as proposed in the Knoxville zoning document.The drafters of the proposed ordinance need to have some one from the city law office read and understand PRB-1. There have been numerous challenges brought in court versus municipalities that have been successfully decided in favor of Amateur Radio operators in the intervening years as a result. An example from 1987, where a municipality was successfully sued by a resident re: PRB-1 violation and not only won the right to erect his antenna system, was awarded $13,800 as plaintiff:Thernes vs. Lakeside Park-Consent Decree, Order and Final Judgement (http://www.qsl.net/k3qk/thernes2.html)Many municipalities have solved this by including language in zoning regulations that says antenna towers or support structures or antenna heights in residential must conform to FCC PRB-1 or have even adopted it as part of zoning regulations. 23 states have adopted PRB-1 laws so far - as have numerous local governments. A Bing or Google search for PRB-1 will bring up relevant information.
Staff Reply:

R-! Changes

I am strongly against the proposed changes to the R-1 zoning. Especially as it relates to ADU's and "Design Facade Requirements". I built my home in a low density single family neighborhood because thats how I prefer to live. Allowing multiple dwellings on a single lot will double the density and congestion in my neighborhood with increased number of cars parked on the streets. It would turn the neighborhood into an Air B&B context with complete strangers coming and going at all times potentially effecting our safety. I thought the city was supposed to "provide safety and security". If the city wants to propose such radical changes it should be put to a public vote or referendum. Let the neighborhoods decide for themselves and not some government bureaucrat !
Staff Reply:

Adus- Hot Topic

Hello, I attended the meeting last night and was saddened to see so many people asking questions in an aggressive and combative way. I think this is largely fear-based and would like to find out what we can do to allow property owners the freedom to have ADUs, even for personal use or for family, while addressing the (often overblown) concerns some have for "doubling the population density", etc. Is it possible to include restrictions such as "Main dwelling is owner occupied only", and also implement some parking restrictions so our narrow streets don't become congested. We're already dealing with several traffic issues as it is in Sequoyah Hills. Would these restrictions fall under the zoning that you are doing, or would that be something for another department? I know people are focusing on STRs, but I see ADUs as beneficial. It would allow someone to rent out a garage apartment to a grad-student or a young couple to help maintain an older home. While I'm not opposed to STRs, I think that that is an issue that should be discussed separately, as one doesn't automatically mean the other. This "fear of strangers" in our neighborhoods is a little ridiculous, but requiring "owner occupied" would help, because most people don't want to deal with strangers in their backyards, basements, etc. Thank you for all you're doing in helping Knoxville prepare for the future.
Staff Reply:

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