Attachment I - Concerns - Z-TA-8-23-Y.pdf

RCVD 6/27/2023
ATTACHMENT I

FROM : Robert Maynard
SUBJECT : Parking space
MESSAGE : I just read where the city council will vote to reduce parking spaces for 
apartments in various parts of the city. I am very much against this. Parking is an issue around 
this city all the time. Look around any school and the residential neighborhoods where the 
neighborhood,is inundated with students, and parents cars. Try finding a parking spot in 
uptown plaza on the weekends and holidays. 
Overall it is a very bad idea. It would have been a good idea if done in the 60s or early 70s but 
not now. 
Thank you for your public service on the council,
Robert Maynard 
524 W. Why Worry Lane
Phoenix, 85021
Email : maynard198@cox.net
AREA : 602
PHONE : 9976640
ADDRESS : 524 W. Why Worry Lane
CITY : PHOENIX
STATE : AZ
ZIP : 85021
Submission ID: 53d14aade3b24416acf98b1c660f80cb
Form Submission On : 7/18/2023 12:24:07 PM
Referer: https://phoenix.gov/district3/contact-district-3
This is Not Spam - This message is sent on behalf of the City of Phoenix.
Please handle appropriately.

1 August 2023  
 
Chair and Commissioners 
Planning Commission 
c/o City of Phoenix, Planning and Development Department 
200 W. Washington Street, 2nd Floor 
Phoenix, Arizona 85003 
 
RE: TA-5-23 (ADUs); TA-8-23 (Affordable and Multi-Family Housing parking reductions) 
 
Mr. Chairman and Commissioners: 
 
Attached with this letter is a correspondence the Neighborhood Coalition (NCGP) sent to all 
Village Planning Committees (VPCs) in July regarding the subject text amendments.  
NCGP representatives presented on the subject at ten of the 15 VPCs.  
Planning and Development submitted to you an addendum to the ADU text amendment. While 
we appreciate the effort to improve the TA, the changes have yet to be aired so we wish for a 
more fulsome public discussion before embracing the changes suggested.  
We continue to stand by our recommendations—amending the ADU TA to improve the clarity 
of its impact on historic preservation districts, special planning districts and overlays, and HOAs 
and CC&Rs. We also think managing short term rentals (STRs) deserves a greater inspection. 
We also believe that the proposed parking reductions to affordable and multifamily housing 
projects warrant substantial amendments to be considered viable on a citywide basis.  Indeed, 
nine of the 15 VPCs voted to deny the reduced parking text amendment as presented to you.  
Please consider the recommendations NCGP has offered you for both TAs. 
 
Respectfully, 
Neighborhood Coalition of Greater Phoenix members and friends 
att.

11 July 2023 
Chair and Committee Members 
Desert View Village Planning Committee 
c/o City of Phoenix, Planning and Development Department 
200 W. Washington Street, 2nd Floor 
Phoenix, Arizona 85003 
RE: TA-5-23 (ADUs); TA-8-23 (Affordable and Multi-Family Housing parking reductions) 
Chair and Committee members: 
The Neighborhood Coalition of Greater Phoenix is registered with the Corporation Commission of 
the State of Arizona and has continuously been a member in good standing since 1984. Our 
members are from neighborhoods across the City of Phoenix.  
Background 
We understand that our nation is facing a housing shortage and that Arizona and Phoenix have 
not been spared from this shortage. NCGP members believe it falls upon all of us to help provide 
relief and a sustainable path forward.   
In that spirit, members of the NCGP working group gathered to review and discuss the proposed 
subject text amendments the City has anticipated to address our housing shortage.  
2023 Arizona Legislative Session 
This year’s session saw several housing bills make their way through the Legislature without 
success. Indeed, NCGP, its members and our partners across the Valley and the state were active 
in seeking ‘no’ votes from elected representatives. Ultimately, the bills were either voted down 
decisively, on a bipartisan basis, or they failed to make their way to the floor of either Chamber.1 
1 Senate bill SB1117 was denied in the Senate on a bipartisan vote, failing 20 to 9 in March. The bill was then 
broken into 3 separate bills: HB1161, HB1163 and SB2536. On the final day of voting in June, SB2536 was defeated 
on a bipartisan basis, 19-10. HB1161 and HB1163 failed to get a vote on the House floor, ending the bill sponsor’s 
push for so-called ‘zoning reform.’

RE: TA-5-23 (ADUs); TA-8-23 (Affordable and Multi-Family Housing parking reductions) 
P. 2 of 7
Neighborhood Coalition of Greater Phoenix 
 July 11, 2023 
We provide this information to let VPC members know that all the text amendments coming 
through committees in the last several months--and now this month—can claim origins from 
the bills at the state legislature that we are intimately familiar with. 
Z-TA-5-23 (Accessory Dwelling Units or ADUs)
Many of us think that ADUs can have a positive impact on the housing supply in our city. Yet, we 
believe that there are several elements of the proposed TA that require additional scrutiny. These 
are our comments and suggestions.
I. Historic Preservation and other Special Planning/Overlay Districts:
We have great concern that the TA as presented will create confusion and contention between 
this ordinance and the ordinances that govern properties of historic significance. Z-TA-5-23-Y 
must state that for historic properties, Chapter 8 of the Zoning Ordinance takes precedence over 
the design review standards for ADUs. Specifically, the proposed language states: 
"(c) DWELLING UNITS ON LOTS ZONED OR DESIGNATED HP ARE EXEMPT FROM THE 
PROVISIONS OF SECTION 8.5, SO LONG AS THE PLANS ARE REVIEWED AND APPROVED 
THROUGH HISTORIC PRESERVATION PRIOR TO ISSUANCE OF ANY BUILDING PERMITS." 
The phrase "so long as..." is imprecise and doesn't make it clear that ADUs in historic districts 
MUST be reviewed by the HP Office. The proposed language is subject to misinterpretation that a 
project may EITHER be approved by the HP Office OR incorporate the Design Guidelines of 
Section 8.5 of the TA.  
To make it clear that ADUs in historic districts must have HP approval, we suggest the following 
language: 
"Dwelling units within a historic district and/or with HP or HP-L zoning overlay are subject 
to review by the City of Phoenix Historic Preservation Office pursuant to Article 8 of the 
Zoning Ordinance. In the event the provisions of Section 8.5 herein, or other ordinance or 
regulations are inconsistent with Article 8 of the Zoning Ordinance (Historic Preservation), 
Article 8 shall have precedence." 
We also believe the proposed TA Section 702.F.1(b) (Special Parking Standards), likewise does not 
make it clear that HP approval is REQUIRED for the addition of parking to the front of a historic 
property (widening of driveways and curb cuts, etc.), and the language should be strengthened. 
The proposed language states: 
"Spaces in excess of those required for single family and duplex residential uses may be 
located in the required front yard. However, all parking and maneuvering areas within the 
required front yard shall not exceed forty-five percent (45%) 50% OF THE AREA OF THE 
REQUIRED FRONT YARD, EXCEPT THAT A DRIVEWAY SHALL NOTBE REQUIRED TO BE LESS 
THAN 18’ IN WIDTH UNLESS OTHERWISE STIPULATED BY HISTORIC PRESERVATION.”

RE: TA-5-23 (ADUs); TA-8-23 (Affordable and Multi-Family Housing parking reductions)  
P. 3 of 7 
Neighborhood Coalition of Greater Phoenix 
 
 
 
 
 
      July 11, 2023 
 
 
 
 
We think stronger language is needed to ensure that Historic Preservation regulation takes 
precedence over the ADU ordinance by deleting, "Unless otherwise stipulated by Historic 
Preservation", and adding the following sentence: 
 
"Any and all changes to driveways, parking and maneuvering areas within a historic 
district and/or with HP or HP-L zoning overlay are subject to review by the City of Phoenix 
Historic Preservation Office pursuant to Article 8 of the Zoning Ordinance. In the event the 
provisions of Section 702.F.1 herein, or other ordinance or regulations are inconsistent 
with Article 8 of the Zoning Ordinance (Historic Preservation), Article 8 shall have 
precedence." 
 
Third, the proposed amendment Section 706.A.3.b (Accessory Dwelling Units (ADU)) is also 
worded in such a way that makes HP approval seem optional.  
 
The proposed language states:  
 
"b. A DETACHED ADU, WHEN VISIBLE FROM ADJACENT STREETS, SHALL BE CONSTRUCTED 
WITH SIMILAR AND/OR COMPLEMENTARY MATERIALS, DESIGN, AND COLOR(S) AS THE 
PRIMARY DWELLING UNIT, OR AS MAY BE APPROVED BY HISTORIC PRESERVATION FOR HP 
ZONED OR DESIGNATED PROPERTIES. (P)" 
 
Instead of using the imprecise phrase, "or as may be approved", the language should be 
strengthened as follows to make it clear HP approval is REQUIRED for historic properties: 
 
Delete the phrase "or as may be approved by Historic Preservation..." and add the following 
sentence: 
“A detached ADU within a historic district and/or with HP or HP-L zoning overlay is subject 
to review by the City of Phoenix Historic Preservation Office pursuant to Article 8 of the 
Zoning Ordinance. In the event the provisions of Chapter 7, Section 706.A.3.b herein, or 
other ordinance or regulations are inconsistent with Article 8 of the Zoning Ordinance 
(Historic Preservation), Article 8 shall take precedence." 
 
II. Parking for ADUs 
 
We agree that the amount of the front yard that can be allowed for parking needs to increase 
from 45% to 50% for parcels that are approved for an Additional Dwelling Unit. We also know, 
based on experience, that on-street parking will become more frequent.  
 
To ensure that property owners in proximity to a property with an ADU is not inconvenienced or 
that use of their property is not diminished, on-street parking should be regulated. Please note 
that homes subject to Historic Preservation, Special Zoning and Overlay Districts are still subject 
to whatever specific regulation(s) applies to those properties per the first consideration in this 
position statement.

RE: TA-5-23 (ADUs); TA-8-23 (Affordable and Multi-Family Housing parking reductions)  
P. 4 of 7 
Neighborhood Coalition of Greater Phoenix 
 
 
 
 
 
      July 11, 2023 
 
 
 
 
Combining on-site and on-street parking concerns, the regulation should read: 
 
“A minimum of 1 parking space shall be available either on-site with adherence to Section 
720.F.1 as amended to 50% of the front yard, or on-street parking that must only be in 
front of the subject property unless the property is a corner lot and side-street parking is 
possible.” 
 
Consideration should also be given to adding language to ensure visibility triangles are 
maintained. 
 
III. Short Term Rental 
 
We appreciate the addition of the paragraph in the revised TA requiring a Restrictive Covenant 
but do not feel it is strong enough to meet the City’s goal of increasing affordable housing supply 
for permanent residents. As currently worded, the Restrictive Covenant will preclude investors 
who own residential property from applying for an ADU, but it does not prevent an owner-
occupied property from renting an ADU on a short-term basis. The consequence will have a 
negative impact on affordable housing for first time renters (e.g., college-aged adults), and 
temporary workers (e.g., traveling nurses), among others.  
 
The Restrictive Covenant paragraph should be revised to add the regulation that ADUs, if rented, 
must be for a term of no less than thirty (30) days. The current City of Flagstaff ordinance states: 
 
(a)The property owner, which includes title holders and contract purchasers, shall occupy 
either the primary dwelling unit or the ADU as their principal residence, unless the 
primary dwelling unit and ADU are allowed to be separately leased or rented in 
accordance with subsection G of this Section. 
 
(b)The primary dwelling unit or the ADU that is not occupied by the property owner that is 
rented or leased shall be for a period of no less than 30 days. 
 
IV. Homeowners’ Associations/ CCRs 
 
The proposed TA does not address coordination with Homeowners’ Associations or Covenants, 
Conditions and Restrictions. By law, these contracts must be honored in addition to municipal 
codes and ordinances. This TA should state that applicants for ADUs must comply with HOA and 
Covenants, Conditions and Restrictions in addition to the provisions of the ordinance. 
 
Z- TA-8-23 (Affordable and Multi-Family Housing parking reductions) 
We understand the desire to relieve what developers perceive as parking ‘constraints.’ We 
generally believe, however, that a ‘one size fits all’ approach to parking reductions does not 
reflect a thoughtful approach for a city of 517 square miles.

RE: TA-5-23 (ADUs); TA-8-23 (Affordable and Multi-Family Housing parking reductions)  
P. 5 of 7 
Neighborhood Coalition of Greater Phoenix 
 
 
 
 
 
      July 11, 2023 
 
 
 
 
Any reduction in the current parking space calculations for multi-family housing, in any district 
and any price category, will put the burden of parking on public streets throughout the city. 
Therefore, any revisions to the current ordinance need careful consideration.  
 
We believe this TA is being rushed through the approval process without such diligence. With the 
goal of working together to find suitable solutions, we make observations and propose revisions 
to the current ordinance as follows: 
 
I. Parking space calculations for multi-family developments should only be based on 
proximity to currently available transportation options. They should never be based on 
the rental rates of the units (I.e., luxury, affordable, market rate, low-income/subsidized). 
It is discriminatory to believe that people who live in lower-priced housing do not have or 
do not want personal vehicles. 
 
 II. Because of the cost of apartment rentals, more units of every size are being shared 
by two or more people, oftentimes housemates rather than couples. Expecting that no 
occupant will have a car, even in TODs and WU code areas, is not based on empirical data. 
 
III. Reducing the on-site parking requirements for multi-family housing might be 
appropriate for residents living in the Downtown Core, Transit Oriented and WU Code 
districts, yet it is not acceptable to residents living outside of those districts.  
 
Phoenix is the second largest city by area in the United States. Because of the lack of 
convenient, reliable public transportation in every Phoenix Village outside of downtown 
and within walking distance of light rail, residents depend on personal vehicles to go to 
work, to the grocery, and to the entertainment venues clustered in downtown.  
 
Those residents who do not live downtown will also need parking to continue enjoying all 
that downtown has to offer. If all the street parking is taken by downtown residents, 
commuting patrons will be deterred from attending events. 
 
IV. Include a requirement that visibility triangles must be maintained. 
A. Reducing on-site parking to encourage more density with potentially small front 
and side setbacks could lead to encroachment on the visibility triangle that is a 
necessity to ensure safety. 
 
V. City-wide Multi-family Parking Requirement 
A. The base parking space requirement should be 1.5 spaces per dwelling unit.  
i. This simplifies the calculation instead of calculation based on size of DU 
ii. Maintains the current requirement as the most frequently built size of 
unit (1-2 bdrm) 
iii. Averages the current requirements (1.25/efficiency; 1.5/1-2 bdrm; 2/3 
bdrm)

RE: TA-5-23 (ADUs); TA-8-23 (Affordable and Multi-Family Housing parking reductions)  
P. 6 of 7 
Neighborhood Coalition of Greater Phoenix 
 
 
 
 
 
      July 11, 2023 
 
 
 
iv. It should not be less than the current efficiency DU requirement 
 
 
VI. Citywide Affordable housing Parking Reduction 
A. Delete this provision because it does not consider proximity to alternative to 
personal vehicle modes of transportation. 
 
VII. Infill Development District Parking Reduction 
A. Delete the calculations entirely 
B. Use 10% bonus density incentive 
 
VII. Walkable Urban (WU) Code affordable housing parking requirements 
A. Required parking should never be “zero” 
B. Parking for handicapped residents should always be required and maintained 
C. It should not be expected that residents living in affordable housing in the areas 
of the WU Code will not have personal vehicles 
D. It should not be expected that residents living in affordable housing in the areas 
of the WU Code will never have a guest with a personal vehicle 
 
IX. Passenger Loading Zones within WU Code 
A. Also require parking of service vehicles (e.g., repair technicians) that require 
more time than the other stated examples 
B. Also require parking for renter move-in/move-out vehicles that require more 
time than the other stated examples 
 
Process: Lack of neighborhood outreach 
In a June 1, 2023, staff report to the City of Phoenix Planning Commission, PDD staff wrote: 
 
Staff obtained input from various stakeholders and held four meetings to review and 
request additional input on the proposed text amendment. Stakeholders included 
individuals from the following organizations: 
• Manufactured Housing Communities of Arizona (MHCA) 
• Manufactured Housing Industry of Arizona (MHIA) 
• Arizona Department of Housing Board of Manufactured Housing Member 
• Affordable Housing/Private Developers 
• Arizona State University, Real Estate Development 
 
While we understand that staff feels the need to reach out to industry representatives to 
understand their position, so, too does staff need to reach out to citizens and neighborhoods to 
understand the issues of the vast swaths of residents who will be impacted by these proposed 
sweeping changes to our housing stock.  
 
Does the City of Phoenix think that simply vetting these proposals—changes that can have a vast 
impact on the existing population—should only be presented to VPCs?

RE: TA-5-23 (ADUs); TA-8-23 (Affordable and Multi-Family Housing parking reductions)  
P. 7 of 7 
Neighborhood Coalition of Greater Phoenix 
 
 
 
 
 
      July 11, 2023 
 
 
 
 
Clearly, some VPCs took issue with the speed and confusion of the proposals of the initial two 
text amendments when they were presented. It appears six of 15 VPCs did not meet quorum on 
the first go-around; yet another VPC did not meet quorum last night. 
 
We ask: How can vast changes to the entire city be vetted by, perhaps, 150 people or less? 
 
Next steps: Approve our recommended amendments 
We have pored over these proposals to identify the gaps and looked ahead to stave off 
unintended consequences. We’ve shared those with you here. Simply approving what’s been 
presented in your packet would be to ignore the serious concerns we’ve presented without 
rectifying those issues.  
 
The Neighborhood Coalition looks to make these TAs the strongest and most applicable they can 
be. We would be disappointed if members simply approved the proposals “as is” because we 
don’t want to see this opportunity squandered for the sake of speed, with all of us missing out on 
something that can truly help our city now and in the future.  
 
Respectfully, 
 
 
Neighborhood Coalition of Greater Phoenix (NCGP) 
Neal Haddad, President, NCGP; Arcadia Osborn Neighborhood Association 
B. Paul Barnes, Vice President, NCGP; AZ APA Distinguished Citizen Planner; former CEVPC chair 
Mary Crozier, President, North Central Phoenix Homeowners Association 
Sandy Grunow, Co-Chair, Mid-Century Modern Neighborhood Association 
Dave Jackson, President, Rancho Ventura Neighborhood Association 
Jack Leonard, architect, AIA, NCARB, LEED AP; 2015 General Plan update committee;  
former Camelback East and Encanto Village Planning Committees 
Michael Phillips, President, Arcadia Camelback Neighborhood Association 
Jackie Rich, President, Murphy Trail Estates Neighborhood Association 
Larry Whitesell, Co-Chair, The Peak Neighborhood Association

1
Racelle Escolar
From:
jvrich@gmail.com
Sent:
Tuesday, August 1, 2023 5:46 PM
To:
PDD Planning Commission
Subject:
Comments on Agenda Items 16 and 7 (Z-TA-5-23-Y and Z-TA-8-23-Y)
Dear Planning Commissioners, 
I am writing this email to urge you to take your time in considering the proposed complex text amendments pertaining to Accessory 
Dwelling Units and Reduced Parking Requirements.  Do not rush into a decision before you are comfortable that what you are acting on 
will not come back and bite you and the city of Phoenix at a later date.   
 
These two text amendments will have a big impact on Phoenix and Phoenicians.  They sprung from the Planning Department, were 
sent to the Village Planning Committees for their recommendations (all of whom are Council appointees), now you, also Council 
appointees, are considering them, and then finally, the Council will act on them.  The public’s opportunity to provide input was neither 
publicized or solicited.  No neighborhood stakeholders were included in their development. While there were articles in the AZ 
Republic about the Accessory Dwelling Unit amendment as early as July 3, the first article on the parking reduction text amendment 
was on July 19, when all but 3 VPCs had already met and made recommendations.  It is also worth mentioning that the agendas for the 
VPCs did not identify Z-TA-8-23-Y as reducing required parking although they identified the other amendment as allowing 
ADUs.  Instead the agenda listed all the sections that needed to be changed so that someone looking at it would have no idea what that 
text amendment was actually about. 
 
The only members of the public who have participated in the VPC meetings are people who serve on a different VPC, work for an 
industry that would benefit from these amendments, or neighbors and neighborhood groups who accidentally found out about the 
amendments.   I have been to five VPC meetings, each of which lasted for as long as 3.5 hours, just to be able to speak for 2 minutes 
max on each text amendment. (Note, some VPCs allowed more time for members of the public to speak - just not the ones I attended.) 
At the meetings I attended, I was not allowed to ask questions.  Following public comments, staff often offered a rebuttal to what 
members of the public said, and after that the public was ignored - no opportunity for any of us to answer questions that came up or to 
respond to incorrect information. It was frustrating. 
 
I have other concerns about the VPC meetings. The packets that were sent to the VPC members online were well in excess of 200 
pages.  Some packets weren’t sent out until after 3:30 pm the day of the meeting; some VPC members never received a packet; other 
VPC members received packets but didn’t read them (perhaps because of lack of time or because of the length). There was a 
questionable email conversation about the text amendments that all VPC members were part of and which was potentially in violation of 
the Open Meeting Law that was referred to at a VPC meeting by several VPC members.  Several of the VPCs did not have a quorum in 
June and so learned about the text amendments for the first time in July when they were expected to vote on them.  
 
Some of the Planning Commission members are essentially in the same position as those VPC members who had the least amount of 
time to learn about the text amendments. They are hearing staff’s presentation about these complex text amendments on the same 
night they are expected to vote on them.  Your consideration of the text amendments will be late in the night after considering 13 other 
cases.  How many hundreds of pages were in your packet?  The text amendments alone are a lot of information to digest in an evening. 
 
These text amendments are too important and consequential to be rushed through and there is no compelling reason to do so.  I urge 
you to take your time and give these text amendments the time and attention that they deserve. 
 
Thank you, 
 
Jackie Rich 
Murphy Trail Estates Neighborhood Association

1
Racelle Escolar
From:
jvrich@gmail.com
Sent:
Tuesday, August 1, 2023 5:55 PM
To:
PDD Planning Commission
Subject:
Comments on Agenda item 17: Z-TA-8-23-Y
Dear Planning Commissioners, 
I am writing with regards to Z-TA-8-23-Y concerning reductions in parking requirements for multifamily housing. 
 
First of all, I find it surprising that in Z-TA-5-23-Y, which would allow Accessory Dwelling Units, one covered parking space per dwelling 
unit is required, while for multi-family housing according to this text amendment, it is acceptable to have .5 parking spaces per unit or 
even zero.  
 
The proposed reductions in required parking spaces may work in some parts of town where light rail is nearby, where stores and 
services are nearby, and in seasons when the temperatures are moderate.  However, it is difficult to imagine that residents living in 
parts of the city like Laveen, Desert View, Estrella Mountain, Ahwahtukee, in neighborhoods that are miles from light rail or convenient, 
reliable bus service will benefit from the proposed reduced parking requirements. Taking away required parking will not reduce vehicle 
ownership.  It will mean that apartment residents must park in the streets and walk to and from their cars.  On street parking is less 
convenient, less safe, less secure than parking in an apartment complex.  
 
It is also difficult to imagine that living within a quarter mile of the light rail would allow people who live in affordable housing to go 
entirely without cars and justify zero required parking.  A quarter mile is a long way to walk in extreme heat even for young people in 
good health.  It would be more arduous for everyone else, particularly people who are disabled with mobility problems.  There is a 
reason that ADA parking spaces are the ones that are closest to entrances to stores and offices - persons with mobility issues can’t 
move very far - certainly not a quarter of a mile to get on light rail. 
 
In addition, there are very few grocery and other retail stores, doctors’ offices, and other services that are located along the light rail. 
Relying on Light Rail also can limit where one can work, as some jobs require the mobile flexibility that, at this time, only a car can 
provide. 
 
It has been argued by affordable housing providers that people living in affordable housing don’t have cars and their parking lots are 
half empty.  That isn’t true, which you can check out by looking at street view on Google maps.   Itt has been argued that developers 
will provide more parking than the requirement if that is in the best interest of their prospective tenants.  My experience as a neighbor 
engaged in land use decisions for more than 20 years, is 9 out of 10 developers will meet the minimum requirements and not go 
beyond them in order to maximize their profits. Only the rare developer cares about creating a quality development that benefits the 
tenants and the neighborhood.  
 
Thanks to the recently adopted Prop 400 that will be going on the ballot in November, there is no funding allocated to expanding the 
light rail system.  So in our best case scenario and Proposition 400 is passed, the light rail will not, in the foreseeable future, serve the 
communities on the edge of Phoenix. If this is all the light rail there will be, do the proposed reductions in parking requirements in this 
text amendment still make sense? 
 
Thank you, 
 
Jackie Rich 
Murphy Trail Estates Neighborhood Association