Flagstaff Commission Demands Trail Visibility on Private Land in Regional Plan Update

Open Space Commission Contests Trail-Map Compromise, Drafts Fourteen Recommendations as Regional Plan Heads to Hearings

On August 26, the Flagstaff Open Space Commission spent more than five hours in intensive line-by-line review of the city-county regional plan update, emerging with a list of fourteen substantive recommendations—and an unambiguous message to the planning apparatus: the softening of planned trail symbols on private land, ordered by city council in May, was a concession the commission cannot accept.

The session revealed the commission's deep concern that property owners had effectively dictated which areas of the regional plan would be implementable and which would remain aspirational. After incorporating 2,000-plus public comments and nearly 800 staff inputs over months of revision, the plan is now in the final stages before planning-and-zoning public hearings on September 10 and 24, with city council review set for October 9. Tonight's work was the commission's last chance to formally shape the document before it exits the drafting phase.

Key Speeches

"When property owners came forward and said we don't want any trails on our property, [staff] rightfully reminded council and the commission that if they do that, we won't have the negotiating power to get those trails in the future, which is why we left the line on." — Sarah Dector, Neighborhood Planning Manager

"This is really we're allowing the land owners to dictate our regional plan right here. We're acquiescing to them because they don't want they didn't want any of the trails shown on their properties, especially the large land owners, and why they got to dictate where a suburban center went right next to an identified sensitive space that open space has declared the Hoffman Tank." — Commissioner Norton (regarding trail-mapping compromise and concern that large property owners influenced both trail visibility and suburban-center designations)

"I still worry about the word significant because the state statute doesn't really say what significant is, right? It did leave it up to us to decide what's significant." — Commissioner Norton, raising concern that undefined statutory language could invite misinterpretation of resource-protection requirements

"When I sat down and saw RPO the first time, I thought this is the most anthropomorphic way to protect natural resources. It has nothing to do with the resource or the ecology, and it's all about the fact that we like our pretty trees." — Sarah Dector, reflecting on how the city's Resource Protection Overlay prioritizes abundant ponderosa pine (favored by residents) over rare or vulnerable ecosystems

"Policies are not measurable. So they could put in very very little and that would still be an increase. Just playing devil's advocate here." — Commissioner Wallen, questioning the enforceability of open-ended policy language like "increase accessibility"

"If you want what's on the map to stay where it is, I would not recommend you provide comment number five, because if comment number five were accepted, I would have to go back through all these parcels and take off ones that were not dedicated for open space." — Rebecca (planning staff), warning that the commission's proposed edit to city-owned open-space language could trigger removal of blue parcels that are maintained as open space despite lacking formal dedications

Timeline

• Applicant presentation (staff): Sarah Dector walked the commission through major changes in the revised plan: elimination of implementation guidelines in favor of a streamlined zoning-conformance flowchart; reorganization of climate and parks language to be more prominent; softening of trail symbols on private land >400 acres; and repositioning of resource-protection guidance from Chapter 7 into Chapter 3 as "best practices" requiring expert consultation.
• Staff recommendation: Dector outlined the statutory limitation under Arizona law prohibiting the city from designating private or state-trust land as open space, and explained that the plan's visual "big bubbles" showing regional park needs are bounded by that constraint. She also presented the revised map symbology showing future trails on large private parcels as non-downloadable polygons (no longer linear data), a compromise reached at the May 2 council retreat.
• Public comment: None. Per notice from Chair Fox, the meeting was limited to commissioner discussion and staff Q&A due to two substantive documents and time pressure (goal to adjourn by 6 p.m.).
• Council discussion / Commission discussion: Commissioners engaged Sarah Dector and planning staff (Robert, Rebecca, Martin) in extended questioning on fourteen proposed recommendations, covering trail mapping equity, ponderosa pine inventory, viewshed management, 10-minute walking standards, resource-protection terminology, and open-space integration with housing and climate priorities. Dector frequently cautioned that certain suggestions would limit implementation or conflict with state statute, existing code, or council direction from May 2; others she flagged as redundant (the language exists elsewhere in the plan). Commissioner Norton, in particular, pressed for consolidation of scattered guidance into high-visibility sections (Chapter 3 rather than Chapter 4) to ensure future decision-makers would find critical language easily.
• Vote: No formal vote on recommendations tonight. Instead, the commission authorized Robert (identified as a planning staff member who has been the institutional memory on the open-space framework) to redraft the letter incorporating both tonight's feedback from Dector and any written comments commissioners submit by September 2. The commission will then hold a special virtual meeting on Monday, September 8, at 4 p.m. to vote on final language before submitting to planning-and-zoning by the September 10 hearing.

Opposition

No organized opposition was present at the meeting. However, Sarah Dector articulated the perspectives and constraints that have shaped staff compromise:

• Main concerns (from property owners and other city departments):

  1. Large private landowners have repeatedly requested that planned trails not be shown on their properties; several have submitted comments to council on multiple occasions.
  2. Departments owning city parcels (water services, storm water, public works) resist language characterizing their property as "open space" because deed restrictions or primary uses (storm-water basins, flood-plain management) may preclude or limit recreational access; calling such property "open space" could create false expectations and legal liability.
  3. Viewshed protection ordinances, without careful "rational nexus" grounding, risk legal challenge; San Antonio's model shows viewshed protection must be limited to specific "platforms" (e.g., protecting views of a landmark from designated vantage points), not citywide.
  4. A citywide ponderosa pine inventory could inadvertently encourage unauthorized cutting of large stands not yet mapped; fire-adaptation priorities favor thinning and selective retention, not blanket preservation.
  5. The Resource Protection Overlay is anthropomorphic and ecologically misaligned; it protects abundant ponderosa pine favored by residents rather than rare or vulnerable ecosystems.

• Most compelling arguments from staff:

  1. State statute limitation: Arizona law explicitly prohibits the city from designating private or state-trust land as open space on the regional plan map. Violations could expose the city to legal challenge.
  2. Implementation effectiveness: Policies that only apply to plan amendments (Chapter 3) reach far fewer properties than guidelines integrated into all land-use categories (Chapters 2–4). Scattering parks and open space guidance across multiple chapters actually makes it harder to avoid, forcing developers to address it no matter which zoning pathway they use.
  3. Dual-use parcels are complicated: City-owned storm-water basins, riparian buffers, and utility corridors serve multiple purposes. Adding "or recreational access" language to the definition is what keeps them on the open-space map; removing it would cause staff to delete numerous blue parcels. Departments that own such property worry that calling them "open space" will trigger expectations for maintained trails and facilities that conflict with the primary use.
  4. Ponderosa pine is too abundant to map comprehensively: Current canopy data does not cover the entire city. An incomplete inventory would mislead property owners into thinking large ponderosa stands don't exist on their land, inviting illegal cutting. Better to pursue fire-adapted forestry practices and selective thinning in clusters (the Forest Service approach) than promise a comprehensive inventory.

Support

The commission itself provided all significant support for the open-space priorities in the plan. No external advocates testified.

• Main themes from commissioners (in favor of the fourteen recommendations):

  1. Trail equity: Differentiating between large and small private parcels when displaying planned trails is inequitable and favors landowners with negotiating power. All parcels should be shown to maintain staff's leverage to integrate trails during development review.
  2. 10-minute walking access is foundational: The standard is nationally recognized and widely adopted; embedding it prominently in Chapter 3 goals (not just scattered in Chapter 4) signals that every neighborhood, not just high-density ones, deserves parks within walking distance.
  3. Open space is a co-priority, not an afterthought: Housing and climate action are core priorities, but the plan should explicitly state that open space, trails, and community integration are co-optimized with housing and climate, not subordinated to them.
  4. Ponderosa pine and resource management matter to fire adaptation: Commissioner Norton argued for a ponderosa pine inventory as an action item, noting that fire-adaptation code changes (anticipated in the Resource Protection Overlay update) will rely on baseline data. Large stands are critical to both ecological resilience and cultural identity.
  5. Viewshed management is a shared responsibility: Limiting viewshed protection to parks and open space alone misses opportunities to integrate view-protection into site planning and building placement, especially in new development.
  6. Early funding and action on greenfield parks: The commission urged acceleration of acquisition and dedication of parks and open space in areas slated for near-term development (like the John Wesley Powell corridor), and a bond or financing mechanism to ensure operations and maintenance funding, not just capital outlay.

• Most compelling commission arguments:

  1. Implementation visibility matters: Commissioner Norton emphasized that language scattered across multiple chapters or sections is overlooked by future planners and developers. Consolidating high-priority guidance into Chapter 3 "goals and policies" (the first place decision-makers look) increases the likelihood it will be applied.
  2. Property-owner direction is antithetical to planning: The May 2 council decision to soften trail symbols in response to property-owner requests sets a troubling precedent. Regional plans are supposed to guide the community's vision, not accommodate individual landowner preferences.
  3. Open space is not secondary to housing and climate: Commissioner Norton noted that at the "LOL" (community discussion event) mentioned during the meeting, attendees pushed back against treating open space as a trade-off. The regional plan should acknowledge that menu items and incentives for developers to incorporate parks, trails, and open space are as important to implementation as housing and climate incentives.

Project Details

• Case number / Document: Regional Plan Update (second draft), city-county joint comprehensive plan revision; also mentioned: Code Concept Report on Resource Protection Overlay (on a parallel but less urgent timeline).
• Applicant / Lead agency: City of Flagstaff Planning and Development Services (lead planner: Sarah Dector, Neighborhood Planning Manager); Coconino County also joint author.
• Timeline for public review: 60-day public review closed in December 2024; over 2,000 public comments and 800 staff comments incorporated. Planning-and-zoning public hearings September 10 and 24, 2025; city council October 9, 2025.
• Scope: Comprehensive regional plan covering land use, housing, transportation, trails, parks, open space, climate action, natural and cultural resources, and implementation framework for the city and county.
• Key substantive changes from prior draft:
  • Elimination of "implementation guidelines" as a standalone category; consolidation into land-use-specific guidelines and policies.
  • Reorganization of climate information into Chapter 1 (visible on cover) and Chapter 10 (renamed "Energy and Climate Change") to address feedback that climate guidance was "buried."
  • Parks and open space guidance reorganized: Chapters 2–4 now integrate open-space criteria into every land-use category rather than isolating in a single section.
  • Streamlined zoning-conformance flowchart (new to this draft) replacing the previous 10-year approach; projects conforming to compatible zoning categories and transportation framework get faster review; plan amendments required only for projects seeking zoning changes inconsistent with the map.
  • Significant natural resources language moved from Chapter 7 into Chapter 3 under a new category called "best practices," signaling that consultation with experts (Game and Fish, foresters, etc.) is required.
  • Trail mapping on private land >400 acres softened to non-downloadable polygons per council direction from May 2, 2025 retreat.
  • New language in employment-area land-use categories permitting parks and open space (unlike the current plan), to enable future business-park and open-space integration in locations like the airport area designated for federal-lands sale.

Vote Breakdown

No formal vote on the recommendations tonight. The commission voted unanimously to approve June and July 2025 meeting minutes early in the session but deferred a vote on the fourteen recommendations pending Robert's redraft and the September 8 special meeting.

• Approval of June and July minutes: Unanimous (Commissioner Mary Norton online; Commissioner Molly Joyce absent; Chair Bruce Fox, Commissioners Cluen, Wallen, and Not White present).
• Recommendations draft: To be authorized for redraft by acclamation (no formal count noted in transcript), pending September 8 vote.

Outcome & Next Steps

What was decided: The commission will not formally approve recommendations tonight. Instead, it authorized Robert (planning staff) to redraft the fourteen recommendations incorporating feedback from tonight's session and written comments from commissioners (due by September 2). The revised draft will be distributed by September 2 to all commissioners for review and written comment.

Special meeting: Monday, September 8, 2025, 4 p.m., virtual (Microsoft Teams or Zoom). The commission will vote on the final version of the recommendation letter, which will then be submitted to the planning-and-zoning commission before the September 10 public hearing.

Presentation at hearings:

• One commissioner will present a three-minute summary at the planning-and-zoning public hearing on September 10 (second-best option: September 24, final hearing). Commissioner Fox indicated he would take the first slot on the 10th.
• All written recommendations must reach the planning-and-zoning email address by September 24 to be included in the hearing packet for council review.
• The October 9 city council meeting will hear recommendations but will likely be the final opportunity for public comment (also limited to three minutes).

Process for incorporating changes: Sarah Dector clarified that:

• Small changes (typos, symbology clarification) can be incorporated as "administrative revisions" (ARA) without a full motion.
• Major changes require a formal motion by planning-and-zoning (or council) specifying "we approve the plan with these changes from [commission], plus these changes from [other body/public]."
• Council retains the final authority to amend the plan at adoption; the open-space commission's recommendations are advisory.

Further work on Resource Protection Overlay and Code Changes: Sarah Dector requested that the commission be included in the zoning-code revision process that will follow council's September 27 direction on the Code Concept Report. She committed to providing full presentations to the open-space commission on resource-protection overlay changes before code revisions are finalized.

Controversies & Context

Trail Mapping and Property-Owner Pressure

The most heated exchange centered on the commission's recommendation (item 11) to remove the 400-acre-threshold distinction on the trail map and to reverse or reconsider the May 2 council direction that softened trail symbols on large private parcels.

History: Property owners with substantial acreage in the planning area—identified in the transcript only obliquely as "large landowners"—repeatedly told city council they did not want planned trails shown on their maps. In response, at a May 2, 2025 retreat, the council directed staff to "soften" the visual representation by converting trail lines (which are downloadable linear data) into fat, non-downloadable polygons on large parcels (>400 acres). The intention was to placate property owners while maintaining trails in the system for future negotiation.

Commission objection: Commissioner Norton, in particular, objected that this created a two-tiered system favoring wealthy or large landowners:

"This is really we're allowing the land owners to dictate our regional plan right here, and this is I really feel this isn't acquiescing to them, because they don't want they didn't want any of the trails shown on their properties, especially the large land owners, and why they got to dictate where a suburban center went right next to an identified sensitive space that open space has declared the Hoffman Tank and then also I would think it's going to upset that rural neighborhood, the Herald Ranch and the River Road residents, again why it's there because they wanted it there."

She argued that the softening of trail symbols removes staff's negotiating leverage to require trail construction or dedication during development review. Once a property owner knows the regional plan shows only a vague polygon, not a specific trail corridor, they can more easily argue the plan does not require a precise alignment.

Staff response: Sarah Dector and planning staff noted that the May 2 direction came after extensive public comment from property owners, and that the city must balance regional plan aspirations against property rights. However, they acknowledged:

"When property owners came forward and said we don't want any trails on our property, [staff] rightfully reminded council and the commission that if they do that, we won't have the negotiating power to get those trails in the future, which is why we left the line on."

Dector also explained the mechanics of implementation: Staff reports to planning-and-zoning and council will disclose whether a proposed development addresses the trails shown on the map, even if softened. The absence of a trail in a development proposal can trigger a plan-amendment pathway, requiring additional scrutiny. But if property owners and developers know the visual representation is vague, the threshold for a "meaningful" omission is higher.

Commission recommendation: Item 11 asks council to reconsider the May 2 decision and restore visible trail lines, with language allowing for "wiggling" (alignment adjustments during development review to accommodate topography, site constraints, etc.). Robert noted that the commission should phrase this as a formal request for "reconsideration" of the council's May 2 decision, not as a complaint about current staff actions.

Hoffman Tank, Wildlife Corridor, and Suburban-Center Designation

A secondary controversy (item 8) concerns the designation of areas adjacent to Hoffman Tank—a critical water source for wildlife on the John Wesley Powell corridor—as a "suburban center" in the revised plan. The commission worried that suburban-center designation (which permits higher-density mixed-use development) would preclude the open-space and wildlife-corridor protections that Hoffman Tank currently provides.

Context: Hoffman Tank is a holding tank used to draw elk and deer; it sits in a sensitive corridor. The John Wesley Powell planning initiative (led by planning-and-zoning director Michelle McNelte, not directly involved in the open-space commission's work) is studying wildlife-crossing safety and is considering whether water placement should shift to prevent a "cul-de-sac of death" scenario on McMillan Mesa, where wildlife trapped on the mesa must cross Cedar Avenue twice to escape, increasing vehicle-strike risk.

Commission concern: Commissioner Norton noted that suburban centers are envisioned as places with "a grocery store and a library and foot paths," not as wildlife corridors. Designating an area as suburban center while a critical water source sits nearby seemed to invite conflicting land uses.

Staff response: Sarah Dector and Rebecca explained that the revised plan now permits parks and open space in employment and suburban-center areas (unlike the current plan, which excludes them). This flexibility allows future development to integrate a business park and community park on the federal lands north of the airport, and similarly allows the John Wesley Powell area to include both suburban density and open-space/trail features. She also stressed that the John Wesley Powell study is ongoing and will likely inform future adjustments:

"You need the John Wesley Powell work to look at it, but there is going to be a wildlife crossing area where they're designing the place where the road is raised up over the floodway so that wildlife can move under there. So to build out this area, some of the wildlife movement is going to change. So Hoffman Tank might not be the best or most appropriate location anymore for water."

The implication is that water placement is not fixed; the regional plan does not dictate the final outcome. The commission's role is to ensure the plan preserves flexibility and does not foreclose open-space and corridor preservation through incompatible zoning.

No formal change proposed: The designation of suburban center near Hoffman Tank remains in the draft; staff noted it reflects input from property owners and planning feasibility. The commission's recommendation (if adopted) would be advisory, signaling that future code and plan amendments should prioritize wildlife-corridor integrity.

"Significant Natural Resources" and Ponderosa Pine Inventory

Another tension emerged over the term "significant natural resources" (item 6) and whether the plan should mandate a citywide ponderosa pine inventory.

Commission position: Commissioner Norton argued that restricting conservation to "significant or uncommon" resources only undercuts equity and climate outcomes in everyday neighborhoods. She proposed broadening language to include "complimentary open space" and to add a ponderosa pine inventory as an action item.

Staff pushback: Sarah Dector explained that "significant natural resources" is a term defined in Arizona statute and is mandatory for regional plans. The city must identify and coordinate significant natural resources with open spaces; this is a statutory obligation. Decoupling the plan from that statutory language would weaken implementation and might invite legal challenge.

Regarding ponderosa pine inventory, Dector noted:

"When I sat down and saw RPO the first time, I thought this is the most anthropomorphic way to protect natural resources. It has nothing to do with the resource or the ecology, and it's all about the fact that we like our pretty trees."

An incomplete inventory could backfire: if the map shows some ponderosa stands but not others, property owners might believe they can legally cut unmarked stands. Better to pursue fire-adapted forestry best practices (selective thinning, retention of old-growth clumps) aligned with Forest Service practices.

Resolution: The existing plan already includes an action item on page 7-12 calling for updates to the Resource Protection Overlay and landscaping regulations to incorporate "urban forestry best practices" and fire-adapted community standards. This language covers the inventory concept without promising a comprehensive map. However, Commissioner Norton expressed concern that burying the language deep in Chapter 7 diminishes its visibility and urgency, especially as the city rewrites its zoning code.

Outcome: The commission will note the concern in its recommendation letter, but staff did not commit to changes.

Viewshed Management and Legal Limits

Item 9 (viewshed management) highlighted a fundamental tension between planning aspirations and legal enforceability.

Commission proposal: The commission suggested that viewshed management be framed as a "shared responsibility" across site planning, building placement, and open-space design—not limited to parks alone.

Staff explanation: Sarah Dector, who has studied viewshed ordinances nationally and helped write scenery-management systems for the Forest Service, cautioned that viewshed protection on private land faces strict rational-nexus requirements:

"I've been trained in it. It is so limited on private land. Um, and I had a whole white paper I put online that may not be online anymore, but I had created a city council report back in 2016 and we had done a full search of like viewshed ordinances across the United States and um, you could have this language and it won't change; you can propose different language. It won't change the fact that there's limitations to our ability as planners to require that."

San Antonio's viewshed ordinance (protecting views of the Alamo) limits protection to four citywide "platforms" (designated vantage points). Flagstaff's 1972 building-height restrictions were calibrated using viewshed analysis, which is why McMillan and Mesa have stricter height limits than downtown.

Outcome: The commission's recommendation was noted but not strongly opposed. Dector suggested the commission could raise the issue when the parks-and-recreation master plan is updated, where viewshed integration might be more actionable.

Core Priorities and the Term "Non-Negotiable"

Item 1 proposed adding language to clarify that open space integration is co-optimized with housing and climate action (the city's two declared core priorities), not subordinated to them. The commission suggested:

"In the five core priorities, the city will co-optimize housing and climate outcomes with open space, trails, and community integration to deliver equitable, health-forward, complete neighborhoods."

The draft plan uses the term "non-negotiable" to describe the housing and climate priorities. Sarah Dector explained that she wanted to use the word "emergency" (reflecting the city council's 2020 declarations of a housing emergency and climate emergency), but the county, co-author of the regional plan, had not declared emergencies, so "non-negotiable" was a compromise:

"I wanted to say like these have both been declared emergencies in chapter 3, but remembering this is a joint jurisdictional document that wasn't language that the county agreed to. So it's kind of in place of emergency like that these are basically and what I kind of what I think non-negotiable means I don't define it anywhere is that if we got through 10 years of implementing this plan and we hadn't made progress on those core priorities this would not be a successful plan."

She invited the commission to suggest alternative words. Robert offered "identified" or "legally required" as possibilities. However, Sarah also noted:

"If you just point out we don't like the term non-negotiable, I don't think council or planning zoning wants to spend 30 minutes figuring out which word to use instead. Suggest something, pitch it."

The commission will consider alternative terminology for the recommendation letter.

Duration

• This item (Regional Plan Review and Recommendations): Approximately 5.5–6 hours, with chair's goal to conclude by 6 p.m. (the meeting ran significantly over.)
• Total meeting: Started at [time not stated]; concluded with adjournment around 6:30 p.m. or later (exact closing time not stated in transcript; meeting ran well over the targeted 6 p.m. close).

Other Notable Items

Code Concept Report (Resource Protection Overlay): The commission received a briefing that work on the Code Concept Report examining the Resource Protection Overlay is less urgent than initially believed. Planning staff director Michelle McNelte confirmed the city has "a long way still ahead" on this parallel effort, which will inform potential changes to tree-preservation and resource-protection standards. The commission will likely revisit this item at a future meeting once the city council provides direction on September 27. Sarah Dector requested that the open-space commission be included in zoning-code revision discussions before final drafts are circulated.

Reclaimed Water Agreement: Robert (or another staff member) noted that a water-flow agreement related to the Bow and Arrow agreement (set to expire in 2030) will go to city council on September 9, 2025 as a work-session discussion item. The agreement affects water flows to Canyon and other identified locations under the current Bonup (Bipartisan Oasis and Natural Vitality Upgrade Program, implied). No action was needed from the open-space commission, but the item was flagged for commissioners' awareness.

Next Meetings: The commission's next regular meeting is September 22, 2025, scheduled as a joint meeting with the Parks and Recreation Commission to discuss topics of mutual interest. Commissioners requested guidance on future agenda items but deferred specifics to a later date.