HomeMy WebLinkAboutCOUNCIL - AGENDA ITEM - 07/28/2020 - MANUFACTURED HOUSING REZONING UPDATEDATE:
STAFF:
July 28, 2020
Ryan Mounce, City Planner
WORK SESSION ITEM
City Council
SUBJECT FOR DISCUSSION
Manufactured Housing Rezoning Update.
EXECUTIVE SUMMARY
The purpose of this item is to review and discuss issues relating to the potential rezoning of properties to the
forthcoming Manufactured Housing (M-H) zone district, including the influence of existing land use policy and a
possible extension of the manufactured housing redevelopment moratorium.
GENERAL DIRECTION SOUGHT AND SPECIFIC QUESTIONS TO BE ANSWERED
1. Should properties designated as commercial in City Plan or neighborhood plans be considered for rezoning to
the new manufactured housing district?
2. What are Councilmember’s views on extending the manufactured housing redevelopment moratorium?
BACKGROUND / DISCUSSION
Both City Plan and the Strategic Plan identify policies and objectives to preserve manufactured housing and
enhance the equitable treatment of manufactured housing residents. Council has also identified manufactured
housing preservation and residents’ rights as a priority, and in August 2019, a 12-month moratorium was adopted
limiting the City’s acceptance of any development application which would result in the loss of units within mobile
home parks while additional preservation tools and residents’ rights strategies are explored.
Since the adoption of the moratorium, staff has been finalizing new preservation tools and resident rights
protections. These efforts include Land Use Code updates to create a new Manufactured Housing (M-H) zone
district and changes to the Municipal Code to clarify and enhance residents’ rights related to retaliation
protections, tree maintenance, utility billing practices, and more. If the forthcoming Land Use Code changes are
adopted, existing manufactured housing communities will be eligible to be considered for rezoning to the new
zone district. Staff is seeking additional direction relating to which manufactured housing communities should be
considered for rezoning based on guidance provided by the City’s comprehensive plan and relevant subarea
plans.
Manufactured Housing Zone District - Rezoning Criteria
Staff previously discussed the design of the new manufactured housing zone district with Council at a work
session on April 28, 2020. (Attachment 1) Staff shared that the new zone district would create a new preservation
tool for manufactured housing communities and reduce the likelihood of park closure due to redevelopment. This
is achieved primarily by limiting the types and intensity of certain land uses available to properties within the zone
district. While the new M-H zone district creates a new preservation tool, the preservation goals of the district
would only come into effect once properties are rezoned.
If the forthcoming M-H zone district is adopted by Council, the City may initiate and consider rezoning properties
containing manufactured housing communities to the new district. At the April 28, 2020 work session, staff
described several evaluation criteria used in the 2013 Affordable Housing Redevelopment Displacement Strategy
report on potential manufactured housing communities to include in a new manufactured housing zone district.
The report included criteria such as the size of a community, the percentage of owner-occupied units and whether
July 28, 2020 Page 2
a property was previously included in the City’s former mobile home park zone districts. Some criteria may be less
relevant when compared to the overarching goals for manufactured housing preservation and most properties
containing manufactured housing communities should be considered for rezoning.
An additional set of evaluation criteria staff wishes to highlight is the land use direction and guidance provided by
the City’s land use policy documents, including City Plan and relevant neighborhood and subarea plans. The
City’s Land Use Code requires quasi-judicial rezonings to be consistent with the comprehensive plan and/or
warranted by changed conditions within the neighborhood surrounding the subject property.
Existing Land Use Guidance for Manufactured Housing Communities
City Plan provides land use guidance through a combination of policies related to the community’s growth
framework and broad illustrations of development patterns for different types and intensities of land uses on the
Structure Plan map. In addition, the City has adopted several neighborhood and subarea plans as elements of
City Plan, which provide more specific land use guidance for neighborhoods and corridors within the community.
Most manufactured housing communities in the City are zoned residentially and designated on the Structure Plan
or within relevant subarea plans for low and medium intensity residential development. A potential rezoning to the
new M-H district for these properties aligns with their existing land use and intensity designations and would also
promote the comprehensive plan’s growth framework and housing policies for the general location of residential
development and to preserve a type of housing underrepresented in the community’s overall housing stock.
Several manufactured housing communities are instead designated for commercial/mixed-use development on
the Structure Plan map and in relevant subarea plans. In general, these designations provide long-term guidance
for development patterns of greater intensity and variety than what is proposed as part of the M-H zone district.
The preservation goals of the M-H district may also conflict with some of the policies and goals found in these
plans which identify commercial areas for infill and intensification opportunities, promote land consolidation and
redevelopment along certain corridors to support infrastructure and transportation improvements, or to support a
broader mix of land uses and services.
Rezoning Options
Based on current land use guidance in City Plan and relevant subarea plans, rezoning of properties containing
manufactured housing communities with residential designations could be considered. These properties represent
approximately 88% of all manufactured housing units in the community and their designations in the
comprehensive plan and subarea plans are consistent with the design and intent of the new M-H district. For
commercially designated properties, a rezoning to the M-H district is not consistent with the current guidance
provided by City Plan or neighborhood plans and there existing zoning would likely remain in place.
If Council desires to consider rezoning the commercially designated properties to the M-H district, staff could
initiate a process to review and amend the comprehensive plan and relevant subarea plans. Such a review would
investigate the possibility of changing land use designations and/or neighborhood-specific policy goals based on
additional stakeholder input and updated neighborhood conditions since the original adoption of these plans.
Updates to City Plan or a neighborhood plan require a recommendation from the Planning and Zoning Board and
Council adoption of an ordinance. The timeline to conduct additional stakeholder engagement and evaluate what
may be competing policy priorities is likely to take a minimum of several months and could significantly lengthen
the overall process to rezone properties to the new M-H district. This timeline would further push the rezoning
process beyond the expiration of the manufactured housing redevelopment moratorium, currently scheduled to
end on August 30, 2020.
Manufactured Housing Redevelopment Moratorium
In August 2019, Council adopted a 12-month moratorium on the City’s acceptance of any development
application that would result in the loss of units in a manufactured housing community. This moratorium was
implemented to allow time for the City to consider and implement new preservation and residents’ rights
July 28, 2020 Page 3
strategies. Following the implementation of the moratorium, staff began researching options and best practices
and presented initial findings to Council at a work session in December 2019.
Council provided guidance for staff to pursue a new manufactured housing zone district and staff originally
targeted implementation of the district and consideration of property rezonings in late spring 2020. Development
of the new zone district standards and initial outreach activities took place in January and February, however,
beginning in March, the COVID-19 pandemic disrupted opportunities to meet with stakeholders, including input
from boards and commissions, which had begun to cancel their monthly meetings. At a work session update on
April 28, 2020 staff shared the timeline for the new zone district and rezoning process had become highly
uncertain due to disruptions caused by the pandemic.
With the resumption of board and commission meetings in early summer and new procedures in place for virtual
engagement activities, staff recommenced outreach efforts and is initiating the Land Use Code adoption process
to create the new M-H district. Upon adoption of the Land Use Code changes, staff is also prepared to begin a
City-initiated process to consider applying the new M-H district to properties through rezoning. The following
meetings/hearings are required to implement the new zone district and complete the rezoning process:
Adopt Land Use Code Changes creating the M-H zone district
• Planning and Zoning Board: recommendation to Council
• Council First Reading
• Council Second Reading
(Potential) Update City Plan and Subarea Plans and review alignment for commercial property rezonings
• Planning and Zoning Board recommendation
• Council First Reading
• Council Second Reading
Rezoning of properties to M-H zone district
• Approval of Council exemption request to allow for quasi-judicial rezoning proceedings to occur using remote
hearings
• 14-day written notice to property owners prior to P&Z meeting
• Planning and Zoning Board recommendation
• 15-day newspaper notice prior to Council
• Council First Reading
• Council Second Reading
These events must occur largely in a linear fashion. Each step should be completed before the next can begin.
Staff anticipates the minimum time to fully complete the process to create the new M-H district and consider
property rezonings is approximately two and a half months. This timeline would be extended further if City Plan
and subarea plans need to be amended to consider rezoning commercial properties. Based on this schedule, the
final portions of the rezoning process will occur after the manufactured housing redevelopment moratorium
expires on August 30, 2020.
While staff is not aware of any imminent plans by property owners for redevelopment of a manufactured housing
community, the expiration of the moratorium before the rezoning process is completed creates a risk that a
property owner could submit a redevelopment proposal under current zoning and absent the preservation goals of
the new M-H district.
Council could consider an extension to the moratorium to allow the overall rezoning process to complete fully
within the redevelopment protections afforded by the moratorium. An Ordinance extending the moratorium would
require two readings before Council and staff would bring its consideration forward in August prior to the current
expiration on August 30. If Council wishes to consider an extension, staff recommends it be of limited duration,
sufficient only to enable the timely completion of the rezoning process.
July 28, 2020 Page 4
Council may also consider allowing the moratorium to expire as currently planned on August 30, 2020. The risk of
a redevelopment application being submitted in the first several weeks after moratorium expiration is partially
mitigated by required development review process procedures. Before a formal submittal is made and accepted
by the City, a property owner must first complete a conceptual review meeting, likely followed by a neighborhood
meeting. Neighborhood meetings require a 14-day notification period and are followed by a 10-day waiting period
before a development application may be submitted. These pre-application steps are likely to result in a minimum
of one-month advance notice before a formal application is submitted.
ATTACHMENTS
1. Work Session Summary (PDF)
2. Powerpoint Presentation (PDF)
281 North College Avenue
P.O. Box 580
Fort Collins, CO 80522.0580
970.221.6376
970.224.6134 - fax
Planning, Development & Transportation
MEMORANDUM
DATE: May 1, 2020
TO: Mayor Troxell and City Councilmembers
THRU: Darin Atteberry, City Manager
Jeff Mihelich, Deputy City Manager
Caryn Champine, Director of Planning, Development & Transportation
Tom Leeson, Community Development & Neighborhood Services Director
FROM: JC Ward, Senior City Planner
Ryan Mounce, City Planner
RE: April 28, 2020 Work Session Summary – Manufactured Housing Zoning &
Residents’ Rights Update
At the April 28th City Council Virtual Work Session, Ryan Mounce and JC Ward provided an
update on work underway to develop a new manufactured housing zone district and information
about recently completed and forthcoming residents’ rights and livability strategies, including the
potential for a manufactured housing licensing system. All councilmembers were present for the
discussion via video conferencing.
The new manufactured housing zone district and additional resident rights and livability strategies
are intended to advance Council priorities to preserve manufactured housing, prevent resident
displacement, and improve livability and protections available to residents in manufactured
housing communities.
General discussion and direction from the work session included:
Manufactured Housing Zone District & Rezoning Criteria
Continuing to develop and bring forward Land Use Code changes to implement a new
manufactured housing zone district as a preservation strategy.
General support for ‘Option A’ for the types of permitted uses that should be included in
the new zone district. Discussion reaffirmed the focus of the zone district to specifically
preserve manufactured housing and minimize resident displacement, which could remain
a partial outcome under ‘Option B.’
Some types of permitted land uses, such as extra occupancy rental houses and primary
short term rentals, may not be appropriate in the zone district or create new business
models that result in resident displacement.
Review and refine the types of criteria staff may use to recommend sites for inclusion in
the new zone district. Criteria such as infrastructure condition could be punishing to
residents in certain communities who would otherwise not benefit from the goals of the
new zone district.
DocuSign Envelope ID: 6C830CF7-EE75-4AA1-9E24-A3E61C7607E5
ATTACHMENT 1
April 28, 2020 Council Work Session Summary Page 2
Manufactured Housing Zoning & Residents’ Rights Update
Several questions or requests for additional information were raised on how the zone
district could impact the potential for resident owned communities, as well as how new
technologies (3D printing or new modular home systems) could supplement the zone
district to improve energy efficiency, building conditions, and levels of overall affordability.
Residents’ Rights Strategies & Licensing
General support for research into mobile home community licensing system with additional
information and detailed options for Council’s consideration to define the specific livability
issues to address, responsible parties, and penalties.
Exploration of mobile home community licensing programs will include analysis of
analogous programs in Colorado communities as well as successful regional models.
Initial research into mobile home community licensing in Colorado indicated programs akin
to business licensing with minimum enforcement authorization rather than a
livability/habitability focus supported by compliance staff.
Licensing and other strategies should seek to minimize the pass-thru of costs and fees to
residents. Licensing and inspection fee rates should be informed by current costs to
residents or park management for addressing livability issues.
The forthcoming mobile home community licensing Council Memo will describe the
process Staff will propose to vet licensing program options that will include input from
external stakeholders, mobile home community residents, and community partners.
Mobile home neighborhood liaisons and community partners are establishing
communication and engagement networks to support discussions of resident owned
community models.
Mobile Home Livability and Community-Building Mini-Grant round two funding is currently
on hold at the recommendation of PDT Finance as the City assesses 2020 budget and
anticipated shortfalls.
Next Steps & Follow-up
Staff will resume and continue stakeholder outreach on both the manufactured housing
zone district and livability strategies following a pause due to the initial response to COVID-
19.
The new zone district will continue to move towards implementation. Staff anticipates
presenting Land Use Code changes for Council’s consideration in early summer following
the resumption of Board and Commission meetings and remote quasi-judicial hearings.
Additional residents’ rights and livability strategies and municipal code changes are
scheduled for Council consideration in Q3 2020. Draft proposed language was included
in Council’s work session documents.
Staff will prepare a memo for Council regarding options and research for a licensing
program and additional resident owned community strategies.
DocuSign Envelope ID: 6C830CF7-EE75-4AA1-9E24-A3E61C7607E5
July 28, 2020
Manufactured Housing
ATTACHMENT 2
Work Session Summary
Manufactured Housing Zone District
Criteria for rezoning; existing land use
guidance
Moratorium
Revised rezoning process & timeline
Implications for moratorium expiration
2
3
Direction Sought
1) Should properties designated as commercial in City Plan or neighborhood
plans be considered for rezoning to the new manufactured housing district?
2) What are Councilmember’s views on extending the manufactured housing
redevelopment moratorium?
4
Manufactured Housing Zone District
Manufactured Housing Zone District
Creates new tool to help preserve manufactured
housing communities
Maintain neighborhoods; reduce likelihood of
displacement
Implemented through Land Use Code updates
Upon adoption, properties could be considered for
rezoning
5
Manufactured Housing Zone District
Rezoning Evaluation
New district intended for existing
manufactured housing communities
~ 1,400 units City limits
~ 2,100 units in GMA
Zoning considered at time of
annexation
6
Manufactured Housing Zone District
Rezoning Evaluation
Staff previously shared potential rezoning criteria from prior studies on a
manufactured housing zone district:
Discussion included that some criteria were less relevant; most properties
should be considered to achieve preservation goals
Size
Presence of Natural Hazards
% Owner Occupied Units
Prior Zoning History / Land
Use Guidance
Stakeholder Input
7
Rezoning Criteria
Rezoning Evaluation – Land Use Code criteria
Quasi-judicial rezonings must:
Align with the comprehensive plan and/or
Warranted by changed conditions in surrounding neighborhood
Additional criteria which may be considered:
Rezoning compatible with existing/proposed uses surrounding property
Adverse impacts on the natural environment
Result in logical and orderly development pattern
8
Land Use Guidance
Rezoning Evaluation
Land use and zoning guidance is provided by:
City Plan Structure Plan map (broad)
Subarea plans (neighborhood-specific)
Land use and zoning guidance indicates:
General land-use categories & intensities
Residential, commercial, high density, etc.
Specific zoning categories
Policy goals & objectives
9
Land Use Guidance
Existing guidance:
Most properties containing a manufactured housing community are
consistent with City Plan / Subarea Plans
Designated for residential development
Identified for low/medium intensity
Surrounded by other residential uses and complementary activities
Promote growth framework and housing policies
10
Land Use Guidance
Existing guidance:
Several properties containing a manufactured housing community are not
consistent with City Plan / Subarea Plans
Designated for commercial or mixed-use
Identified for higher intensity development
Surrounded by other commercial uses and activities
Other policies seek to promote
Infill / intensification along major corridors
Infrastructure and transportation enhancements
Land consolidation and greater mix of uses
11
Options
1) Consider rezoning residential properties in alignment with City Plan /
Subarea Plans
Represents ~88% of City’s manufactured housing units
2) Consider rezoning both residential and commercial properties
Rezoning commercial properties not aligned with City Plan / Subarea
Plans
Requires additional process to amend policy documents
Understand policy implications of change in designation
Additional outreach with stakeholders
Adds additional time to rezoning process
12
Moratorium Overview
Moratorium Established
Limit the City’s acceptance of development applications
Allow time to research and adopt preservation & residents’ rights tools
One-year; expires August 30, 2020
Work Underway
Resident’s rights – August Municipal Code changes
New M-H zone district – August Land Use Code changes
Rezoning process – August/September
13
Preservation Timeline
Original Timeline
Develop standards
Outreach / feedback
Adoption
Jan Feb Mar Apr May June July Aug Sep Oct
Moratorium
Expires
14
Preservation Timeline
Revised Timeline
Develop standards
Outreach
Adoption
Jan Feb Mar Apr May June July Aug Sep Oct / Q4
COVID Delays Outreach
EngagementExpires Impacts Moratorium
Reduced stakeholder input opportunities 2-3 months
Cancelation of Board & Commission meetings
Additional rezoning engagement planned: ongoing owner/manager
conversations; virtual neighborhood meetings
Commercial
Rezonings
Commercial
Rezonings
15
Moratorium Impacts
Moratorium Expiration: Impacts & Risks
After moratorium expires:
Property owners could submit redevelopment application under
current zoning
Mitigation
Requires 30+ days of pre-submittal work before submission of
application
Conceptual reviews, neighborhood meeting, notification & waiting periods
16
Moratorium Options
1) Allow moratorium to expire; complete rezoning process as soon as possible
2) Consider extension of moratorium to allow rezoning process to complete
within moratorium protections
Requires two readings before Council
Recommended extension: 2 – 4 months
17
Direction Sought
1) Should properties designated as commercial on the Structure Plan map be
considered for rezoning to the new manufactured housing district?
2) What are Councilmember’s views on extending the manufactured housing
redevelopment moratorium?
18
RESOURCE SLIDES
Zone Development Timeline
19
City Limits
Manufactured Home Community
GMA Boundary
City GMA Total
Communities 10 14 24
Home Sites 1,400 2,137 3,537
Manufactured Housing Community (MHC)
Locations in the Fort Collins GMA
Zone Development Timeline
20
City Limits
MHC in Residential Zone District
MHC in Commercial Zone District
Existing Zoning (city limits)
Residential Zoning
6 located in Low Density Mixed-Use Neighborhood
(LMN) District
1 located in Neighborhood Conservation Buffer
(NCB) District
Commercial Zoning
2 located in Service Commercial (CS) District
Mixed Zoning
1 located in two zone districts (CS & LMN)
21
Existing Standards
Existing CS & LMN Zoning:
No manufactured housing specific standards
Rely on ‘General Development Standards’ in Land Use Code
Wide variety of permitted uses and intensities
CS LMN
95 permitted uses; mostly
commercial
No density maximum
3-story height limit
43 permitted uses; mostly
residential
Maximum density of 9 dwelling
units/acre (12 if affordable)
3-story height limit
22
Existing Conditions - Density
Community Zoning Size (ac.) Units DU/Acre
Skyline LMN 25.68 172 6.69
Hickory Village LMN 30.31 204 6.73
North College (College Frontage) CS 12.84 150 11.68
North College (Rear Half) LMN 22.38 172 7.68
North College (Overall) CS/LMN 35.22 322 9.14
Stonecrest CS 2.26 24 10.61
North Star LMN 4.26 54 12.67
Harmony Village LMN 71.46 486 6.8
Pleasant Grove LMN 12.53 114 9.09
23
Existing Conditions – Perimeter Setbacks
Community Perimeter Setbacks
Skyline 20’
Hickory Village 0‐5’ (buildings off‐parcel: Soft Gold Park)
North College 0‐5’
Stonecrest 0‐5’
North Star 10‐15’
Harmony Village 15‐20’ (side); 5‐10’ (rear)
Pleasant Grove 0‐5’
24
Existing Conditions – Unit Separations
Community Min. Unit Separations
Skyline 10‐15’ (side to side); 15‐20’ (end to end)
Hickory Village 20‐25’ (side to side);
North College (Overall) 10‐20’ (side to side); 5‐15’ (end to end)
Stonecrest 5‐10’ (side to side);
North Star 10‐15’ (side to side); 0‐5’ (end to end)
Harmony Village 15‐20’ (side to side); 10‐15’ (end to end)
Pleasant Grove 15‐20’ some as low as 5’ from accessory buildings to unit (side to side)