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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Accessory Dwelling Units

I live in South Knoxville, and I want to voice my robust support for allowing accessory dwelling units on existing properties.
Staff Reply:

Min Lot Width Prevents New Housing In Rn-4

There is an issue with minimum lot sizes not matching existing lot sizes in the city. RN-3 and RN-4 are the densest residential zones near the corridors, and they are less dense than the historic city grid. There has been much talk about zoning by current use so that these houses will be conforming to the new code, but if you look at the only swathes of RN-3 and RN-4 just north of downtown and well within walking distance (surrounding Baxter @ Central and West end of Gill), the lot widths are 40', 42', 37', 30', (even 22'!) etc. Even in Fourth and Gill there are many lots less than 50' and are thus nonconforming. RN-3 and RN-4 both require 50' minimum for a single family. So as it exists, what appears to be the densest housing areas near downtown and within walking distance to jobs do not permit even single family development. I own a lot on Hinton Ave, on which I currently plan to build a duplex. With the current proposal, I could build no housing at all. I know of another planned development in this area, a quad-plex, which is currently permitted but would not be under the proposed ReCode. Even on this property, a block in from Central and over 60' wide, a maximum of only three units can be built. This result seems both counterproductive and contrary to the goals of your research. I have not reviewed this condition in other areas of the city, so please look closer at this issue elsewhere. It is difficult enough to find one lot for purchase in the area, so anticipating the combination of lots for greater opportunity is not viable. One solution may be to match the required minimum lot width with the existing grid in city neighborhoods, or allowing for an exception for historic widths. Another thought is that these areas near the intersection of Broadway and Central could become a commercial or I-MU district, which has no minimum width and now permits single-family, and matches the historic use of this area. Also, while checking the I-MU district for applicability in these areas, I noticed that single family and multi-family are permitted, but townhouses and duplexes are not. Is there a reason to dis-incentive the middle-density options?
Staff Reply:

Sw Parking Lots In Recode

We have lost the requirement that surface lots in the SW must be in the rear.  This was missing in the July draft.  I commented about it and it was included in the October draft.  Now it's gone again - compare page 11-4 in the Oct. and Dec. drafts.

This, as you know, is a major deal.

Honestly, I wasn't reviewing the current draft to see if corrections made had been unmade.  However, it looks like that kind of review is necessary.

Staff Reply:
Thanks for catching this. I will forward to the consultants and make sure they correct it and do a thorough review of the entire SW code.Regards,Gerald

Parcel 119dd003 / 0 Mars Hill

I own the parcel above and do not want it rezoned RN1. It borders a high traffic road so it will not support single family homes but will need townhomes or some other type of higher density product to be viable. We purchased the property under RP1 designation which allows for 23 units on this property. Rezoning as proposed will negatively affect value of the land.
Staff Reply:
According to the official zoning map of the City of Knoxville, the property at 0 Mars Hill Road is currently zoned RP-1 at less than 6 dwelling units per acre (see attached). The RN-1 designation would allow 4 dwelling units per acre, which would be a reduction n density. We will change the proposed designation to RN-2, which would permit up to 8 dwelling units an acre (an increase in density).Upon approval of the updated zoning ordinance, you may wish to consider requesting RN-4 designation for the property. This change would require a zoning amendment, a sector plan amendment, and a one year plan amendment.

Established Form Base Code Changes

In attending several of the meetings, it was mentioned that there would be no changes to the Cumberland and South waterfront codes since they had both been newly created and publicly vetted. However, there have been changes and I feel the property owners should be alerted to those changes so they could see what impact it may have on development / investment plans. Why not leave them as they were? At quick glance it appears height, set backs and even sign ordinances have changed and I haven't had time to delve into all the details so it leads me to believe there is enough reason to send out postcard alerts to those affected so there may be more feedback since these areas where thought to be not changing at all.
Staff Reply:
Any changes in the form district code that may have shown up in the drafts were inadvertent and the result of trying different approaches to formatting the standards. We have incorporated the form district codes (Cumberland Avenue and South Waterfront) into one article, article 7, and are working to make sure all parts of the form district codes are included and unchanged. We likely will put the parking standards for the form districts in article 12, which has all parking standards, rather in the form code article.Thanks for your interest in the community and in Recode.

Rv Parking And "screening"

I've just reviewed the section regarding RV parking (at a residence) and wonder if anyone on the commission owns an RV? Although I do not store my 13'2" tall RV on my property as it won't fit, I have neighbors that can and do. Based on the requirement to "screen" RVs from public view (from the right-of-way) you are going to require VERY TALL FENCES/WALLS not to mention expensive. Are the commissioners the owners of fencing/wall companies??? The typical travel trailer is about 12' tall and would require at least a 12' tall fence/wall - either that or "hide" the RV in a storage facility (owner of those as well?) or sell it (RV or house). I'm fortunate to be able to afford such luxury of indoor storage, but I doubt the typical RV owner can or is willing to do so. My issue is more with what my(our) neighborhood is going to look like with, say at least half-dozen, homes with 12' tall fencing, just to hide their RV. I'm sorry, but I'd rather you hide some of the ugly cars from sight than a well cared for RV. Since my home is "down the hill" from a right-of-way street, my back yard can be seen from above and would require, by my estimation, a 40-50 foot tall fence/wall to "hide" an RV from view. I and others feel you are trying to weed out RVs and/or RV owners from Knoxville in an effort to beautify Knoxville residential areas. Again, I do not store my RV at home, although I would rather do so. I have thought about relocating to a home where I could expand and store the RV at home, and am now seriously considering it, HOWEVER, I am no longer looking in/around Knoxville or Knox County - our politicians have run me off. I'm glad Knoxville is looking to tell America that RVs, RV owners, and the like are not welcome here - I'll spread the word from a more RV friendly county. Regards!
Staff Reply:

Map Draft 4 Comments - Belle Morris Community Group

Good Morning Gerald & ReCode team-My apologies that these comments were not sent on Friday, I had it all ready to go Friday evening and intended to send when I got home, but it managed to slip my mind over the weekend.Attached is a marked up ReCode map and diagram of Belle Morris and surrounding properties, noting our overall comments/requests/recommendations for each individual parcel within our neighborhood boundary (which is a fluid line at this point) as well as contributing properties along the neighborhood's edge. Our team has spent a great deal of time going through parcel by parcel, studying the historical condition of each property, it's vicinity to other zones, ownership on KGIS, as well as restoration/redevelopment potential as we see (and hope) the neighborhood progresses over the next 10-20 years.We hope that you might carefully consider our recommendations as you finalize the ReCode map. We have not gone through online and marked each of these parcels (for time's sake) however can do so if you are needing further explanation/detail on specific parcels.
Staff Reply:

Request For Postponement Of Agenda Item 5, 11-a-8-oa

It has come to our attention that the Community Forum has requested Agenda Item 5, 11-A-18-OA, Consideration of the Comprehensive Update of the City of Knoxville Zoning Ordinance, be postponed from the January 10, 2019, meeting of the Planning Commission to the February 14, 2019, meeting. The Knox County Democratic Party Progressive Action Committee fully supports such a postponement for reasons similar to those outlined in the Community Forum letter. We urge you to make such a postponement.
Staff Reply:

Recode Text Changes

Attached are the comments from the City.

Staff Reply:

Agenda Item 5, 11-a-8-oa

The board of Ftn. City Town Hall, Inc. agrees with and supports the request of Community Forum regarding Agenda Item 5, 11-A-18-OA- Consideration of the Comprehensive Update of the City of Knoxville Zoning Ordinance. We are asking for a postponement from the January 10, 2019, meeting of the Planning Commission to the February 14, 2019, meeting.The last draft was only available online December 17, 2018, with hard copies available December 27, 2018. During this busy season of the year, it is not practical for neighborhood groups to be able to meet for extensive periods of time to discuss this important document that affects every parcel of property within the city limits. We could not possibly have written comments within the time period allotted, which was January 4, 2019.We certainly intend to offer comments as soon as possible.There are many substantive changes from Draft 3 to Draft 4. The time that Commissioners, the Stakeholder Committee, and the public has had for review has not been long enough for a thorough review.Please don’t vote to accept this document in its present form. We must get this right. Our neighborhoods are in great part what makes Knoxville so special. It is too far-reaching and too important to adopt and then “hope” we can amend the document in problematic areas to prevent damaging impacts to our neighborhoods and even commercial areas.Again, we are asking for Agenda item 5 to be postponed until the February 14, 2019 Planning Commission meeting.Sincerely,Board, Ftn. City Town Hall, Inc.
Staff Reply:

Landscape, Lighting And Design Standards

Hello Recode Team,My understanding is that stronger standards for landscaping and lighting are not being included because of enforcement concerns. I would like to suggest that MPC take over that role because it makes a lot of sense for them to do it.I hope you will reinstate design standards for residential areas as well.
Staff Reply:

Kcdp Pac Comment Submission On Recode Knoxville Draft 3 Map And Draft 4 Text

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 3 and ReCode Text Draft 4.

We would especially like to point out our recommendation that the Planning staff seek out more lots to designate as RN-3 or RN-4, focusing on lots within a quarter-mile of core and local bus route stops that have no structures and/or that have non-historic structures that were built more recently, for example since 1980. We would be happy to partner with you and neighborhood groups to find such lots suitable for RN-3 or RN-4, and we look forward to following up with you about this.

Below is the list of PAC members that ratified this comment submission:

Emily Gregg - KCDP Chair & TNDP Executive Committee Member

Allie Cohn - PAC Co-Chair & KCDP Secretary and Executive Committee Member

Michael Davis - PAC Co-Chair & KCDP Executive Committee Member

Sylvia 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 Member

Moira Connelly - PAC Steering Team Member

Matt Sterling - PAC Member

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

Staff Reply:

0 E Fifth Ave Is Not Community Garden

I have commented on the last two maps without response and hope to receive it this third time. The empty lot (0 e fifth Ave) next to 2080 e fifth Ave is incorrectly labeled as the Parkridge Community Garden. The garden is across the street in the open lot, which has been given the correct proposed zoning for such a space. As the owner of the incorrectly labeled lot, I am concerned about liability on my property if something were to happen to someone who mistook it for public use.
Staff Reply:

Recode Timing Is Way To Fast

Why is the comment period so short and over the Holidays? Is Donald Trump now our Mayor and we'll just push this through lickety-split while no one is watching? I've read a few comments on draft #4 with its over 700 changes and one theme appears over and over and over again: there hasn't been enough time to read it! This isn't Congress, this isn't the Trump Administration--this is LOCAL. We need more time to discuss such huge changes. An H1 effort in Parkridge spanned FIVE YEARS of continual meetings, planning, debates, door-to-door knocking, mailers, flyers, everything short of writing it in the sky with an airplane (which Councilman Brown insisted would still result in someone saying they never heard about it) and yet it was smacked down by Mayor Rogero for needing "more discussion time". If FIVE YEARS isn't long enough for a neighborhood of a few hundred acres, how is the measly 7 months this has been public (since the June 2018 release of the maps--everything before that wasn't very useful for the public) long enough for a city encompassing 104.2 square miles? The obvious answer is that either the public doesn't know what it wants and the City needs to tell us what we want or the public wants something contrary to what the Mayor, Mr. Lyons, and the political/developer machine want.What's the rush? Parkridge was told that we have plenty of time to go block-by-block over many years to protect affordable housing; Knoxville already has a zoning code that's worked well enough for 50 years so there's no desperate need to install a zoning code. City Council didn't have a problem pushing the Parkridge H1 off onto a new Council but now the excuse for the rush is so that the next council won't have to deal with it. A project this monumental should take place over several sitting City Councils. I am saddened that is has become just a political plum for an outgoing administration.
Staff Reply:

Rn-2 Density

Though patches of RN-3 and RN-4 now occur on the map in the outer rings of downtown, most existing neighborhoods remain RN-2. I feel these neighborhoods should be zoned a higher density, like RN-3. However, if they are to remain RN-2, I believe they should permit duplex development by right. I suggest RN-2 AND RN-1 be modified to permit duplex development because they would allow increased (from that currently proposed) housing opportunities. The ReCode team has consistently proposed lower density in these neighborhoods than is currently permitted, which counter-acts many well-researched studies demonstrating that the "missing middle" housing is at the core of our nation's housing crisis. If this code is to be sustainably productive, it should permit some "missing middle" opportunity in these neighborhoods (Mechanicsville, Oakwood/Lincoln Park, etc).
Staff Reply:

Please Do Not Zone Historic Eligible Blocks Higher Density

On the 1400 block of Woodbine, a few of the "last" shotgun houses in Knoxville still stand. Zoning these RN-4 invites demolition. There has been a request to please avoid placing higher density zoning on areas eligible for historic districts, because higher density base zoning could create an incentive to demolish historic single family homes where H or NC zoning has not been enacted. The 1400 block is eligible for H or NC overlay, as per the 2016 MPC Study on Edgewood-Park City Historic District. Please see: and
Staff Reply:

Plans Review By Mpc Staff

Due to staffing levels devoted to the review and enforcement of zoning codes, the review of plans and their subsequent enforcement is a heavy lift for many municipal governments. Like most cities, Knoxville has opted to reduce this burden by reducing standards and operating on a complaint driven system. Another option would be to reduce the burden by allocating some of these responsibilities to qualified MPC staff. MPC staff already review design guidelines in certain zones. They are also willing to take on the review of landscape plans.This would make it easier to restore basic design standards for single family dwellings and for landscape standards to be upgraded to include more landscaping in smaller parking lots, a 2-year landscape bond and a tree bank.
Staff Reply:

Recode Effect On East Knoxville

I hope that MPC and the City really think hard about how this recoding of Knoxville will ultimately effect the people that live on the east side(Park City).Just to create density for the sake of more housing may do more harm than good. East of downtown has at this time very little to offer anyone that is low income.There are few jobs and the ones that are available are minimum wage, which at the rate of cost of living two people making minimum wage can not afford housing. There are no grocery stores, its a food desert, unless you have your own transportation. And now that St Mary's has closed there is no medical provider on the east side of town. And none of this is going to change because for any business to locate in any area they are going to look at the median income, so if the city keeps concentrating low income in the 6th district we are not going to attract any future businesses. The city and county need to spread out the low income density across the area so these people will have the availability to be able to help themselves out of their current situations. there was a study done to test the effect of the zip code inwhich you were born, born in a poor zip code you are pretty much doomed.MPC and City, think long and hard about what your are about to do, the effects will last for decades!
Staff Reply:

Recode, Zone Map

I attended the last work shop on 1/3/19 for the recode, I do have some issues with the latest draft. My area has been rezoned back to RN2, but the lot size for a duplex has been lowered from 10,000 sqft of lot space to 7,500 which is the standard size lot in most historic neighborhoods. I do not have an issue with someone wanting to build a NEW duplex that would fit into the character of the neighborhood. But my fear is that we will go back decades inwhich every foot of building space will be converted into "living" area, porches and balconies, will be converted into bedrooms and bathrooms as in the past. We here in Parkridge have spent years trying to over come this exact same type of over crowding and destruction of the historic fabric of our neighborhood. With only small portion of Parkridge protected by a historic overlay and no in fill housing guidelines, we would be damned to repeat our very bad past history. Parkridge would is better suited for RN3 like other historic neighborhoods like 4th and Gill.Also on a technical note, I noticed that under the minimum interior side setback has been changed to a minimum of 20', on a 50' wide lot, as in most cases in historic neighborhoods that would limit the buildable area of 30' wide. I think as it stands now, the minimum is 5', and minimum of 12' combined.
Staff Reply:

Very Old Houses & Multifamily Zoning

While the current Recode map is improved, there are some issues that still need to be addressed in the oldest neighborhoods (those with houses 100± years old). If houses in these neighborhoods are slated to be made into multi-family units, there MUST be required oversight from professionals who have demonstrated knowledge with older home construction. It is in no one's best interest to continue to demolish houses that become condemned because of "renovations" made by using construction techniques that are not adequate or appropriate for these older homes. The current flurry of "renovation" activity by "flippers" in these neighborhoods (Parkridge is one example) is showing that City codes enforcement is not able to prevent structural damage to older homes. There already is a proposed lawsuit because the exterior walls are collapsing on a house in which the framework was compromised by removing load bearing walls and collar ties.Not only is this problem frightening for the new occupants/owners of such unsafe houses, it is frightening for the older neighborhoods that have struggled to rebound from serious blight created by derelict and condemned houses. The history of neighborhood decline that led to condemnation and subsequent demolition of many older homes was directly related to dividing these older homes into multiple apartments. The structural integrity of houses often was compromised by cutting holes in floor joists and rafters for the sake of running multiple pipes, vents, and wiring to accommodate multiple bathrooms, kitchens, and HVAC systems in houses that originally were built without these kinds of modern conveniences - even for one family. Floor plans also were changed to make apartments, porches were enclosed (even sleeping porches, aka balconies), and additions tacked on to make additional rooms. Anyone who has seen, or worked on, one of these houses knows that there either was little to no oversight from codes enforcement, or adequate codes did not exist when such changes were made.A requirement that before a building permit is issued, an architect or engineer (or both) has to sign off on any plans that propose dividing a house that was constructed as single family home and is 80 or more years old, or is a contributing structure in a National Register of Historic Places District, is one way these problems might be lessened. There simply MUST be a process for someone with demonstrated knowledge about older house construction to review plans (including a site visit) proposed for the substantial changes that have to be made to safely create multiple apartments in these very old houses. In addition, there is a need for opinions from two engineers as to whether or not one of these old homes has to be demolished. Very few of them were built with the kinds of foundations that are used today and some are being unnecessarily demolished because some engineers do not know about the older methods.
Staff Reply:

I-mu Should Not Be For Old Buildings Only

Section 6.1 of Draft 4 says that the I-MU zoning district is intended to allow a mix of light industrial uses and a variety of compatible commercial as well as residential uses. Great! But the draft also says that "this mix is intended to promote the reuse of older, character-giving structures that may no longer be suitable for their original industrial purposes " I hope that I-MU can be used for other settings as well.. A mix of craft industrial with commercial and residential may be desirable outside of downtown Knoxville in buildings intentionally designed for this purpose,
Staff Reply:

Fire Safety And Ada

Just finished a quick reading of Draft Four and I noticed several issues that conflicts with fire safety and American with Disabilities Act.After the Gatlinburg Wildfire, the Tennessee Department of Commerce and Insurance, TN State Fire Marshall, TN Division of Forestry, U.S. Forrest Service, International Association of Fire Chiefs, Appalachian Resource Conservation and Development Council, and the National Park Service are all promoting FireWise community planning to reduce wildfires. The current draft mandating landscaping is in conflict with FireWise standards, putting many residents in danger. A few examples of dangerous conflicts are:Requiring far too many trees near residential home. FireWise minimum standards states that trees canopies should be separated by a minimum of 10' to reduce fast spreading canopy fires. Shrubs should be separated by two times their height and if under a trees canopy by three times its height. These distances are based on a flat plane. If structures are located up slope from the landscaping the distance increases as the slope increases. The requirement that townhouses have landscaping along foundation and to screen outdoor equipment is a high risk. If the equipment malfunctions or sparks it could quickly set a wildfire. After the Gatlinburg Wildfire there were several seminars in the area on planning a FireWise Community. Many of the state and federal departments listed above provided presentations. While the state didn't seem ready to mandate FireWise at this time, it was understood that insurances companies may cancel some policies in high fire risk locations. In mixed-use districts the new codes mandates commercial on the first floor while restricting residential to the second floor or above. There are no requirements for elevators therefore the handicapped and seniors will be unable to live in that district. Draft Four has more than 700 changes, I stopped counting after 700. While many are single word changes, sometimes it major changes to a specific zoning. In December, MPC postponed hearing the new ordinance for 30 days. It's scheduled for January 10, 2019, that's 28 days. MPC also notified the public by email on December 20, 2018 that Draft Four was posted. With comments closing on January 4, that allows the public exactly 15 day to read the proposed ordinance and make comment, while many are spending the Christmas holidays with family.
Staff Reply:


I support the effort to "raise the bar" in ordinances concerning landscaping and development, specifically as they apply to requiring developers to landscape parking areas and to contribute toward a mitigation fund or tree bank. I understand that staffing limitations make enforcement difficult, but having it on the books is at least a first step toward being a good steward. Thank you!
Staff Reply:

Comments On Recode Draft 4

Please see the attached letter addressed to Gerald Green for our comments on Recode Draft 4.

Staff Reply:

Recode Knoxville

Over the past days I was reviewing the 4th version on Recode and would like to ask why Materials are excluding from being used in zones?  I strongly disagree with any exclusion of materials.  Having just worked on a project in Muscle Shoals, AL recently there was a material exclusion and it was going to cost the owner 40% more for his typical building by changing material.  We went in front of City Council and they understood our issue and allowed the material. 

How do you think Sequatchie Concrete Services on Sutherland Avenue in Knoxville would feel if CMU is exclude as a material in the city they do business in? Or what about other companies located in Knoxville that makes a forbidden material are you wanting them to leave the area? That doesn’t make planning since.  If you want better design this isn’t the way to go about it. 

I ask that you exclude any building material references in the new zoning ordinance.

Staff Reply:
The restriction on materials was proposed by the consultants assisting with the zoning code update based on their experience in other cities and research done by them. We are still revising the materials restrictions to further reduce and clarify the restricted materials, with input from AIA-ETN. Please note that the restrictions are only for the facade that faces a public right-of-way and only in certain zoning districts. In the downtown district, the Downtown Design Review Board can waive the restriction on materials. In the other districts in which materials are restricted, they can still be used for up to 25% of the facade. Our goal is to ensure the ability to use a variety of materials in all structures.--Response from original poster:I appreciate your response and I have spoken with John Sanders the AIA representative and he was the one who told me to reach out to you. Limiting materials is not what a zoning ordinance should encompass. The Ordinance does not get updated very often as you can see with our current one. For example, you want to exclude plastics from commercial zones. I am the chair for the School of Architecture Dean’s Board, did you know we printed a House out of plastic? It won several awards nationally see the link This technology will only grow. My point is materials constantly update and change, just look at the plastic house. Let architects decide the proper materials not planners.

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