Flagstaff unanimously approves three HOH permits, two code amendments streamlining adaptive reuse

Planning & Zoning Commission Fast-Tracks Three HOH Approvals, Green-Lights Adaptive Reuse Incentives, and Launches Regional Plan 2045 Citizen Review in Marathon Session

On August 27, 2025, the Flagstaff Planning & Zoning Commission approved six items in rapid succession—three high occupancy housing conditional use permits, two major code text amendments, and the minutes from the prior meeting—before pivoting to an extended citizen review session on the draft Flagstaff Regional Land Use Plan 2045. The Commission approved all items unanimously and positioned itself to oversee the final vetting of a comprehensive regional plan that consolidates nearly two decades of policy into a streamlined, priorities-based framework intended to guide housing, climate action, transportation, and land use decisions through 2045.

Three Conditional Use Permits Approved in Minutes

Associate Planner Dustin Stifler presented three single-family high occupancy housing CUPs from Pine Run subdivision, each triggered not by bedroom count but by the number of bathrooms. The first, PZ2500134, involved a 4,792-square-foot home with five bedrooms and five bathrooms on a 46-acre lot. The second, PZ2500133, at 3742 South Woodland Hills Drive, proposed five bedrooms and six bathrooms (receiving one public comment in support). The third, PZ2500135, at 3646 South Woodland Hills Drive, proposed six bedrooms and six bathrooms.

All three received no opposition and had been noticed with property postings, mailed notifications, and a public notice in the Arizona Daily Sun. Commissioner Mary Norton thanked the applicant and Stifler for participating, noting:

"Maybe we should explain a little bit how this happens. These estate homes get caught up in the HOH. Um and that's why they come forward to us. Um because they have a fit bathroom." — Commissioner Mary Norton

The Commission moved through all three approvals in under ten minutes. When the item concluded, Commissioner Norton remarked:

"I'm glad I don't have to clean these homes." — Commissioner Mary Norton

(in response to the scale of the properties)

All three CUPs were approved unanimously with the standard condition that development shall substantially conform to plans as presented.

Adaptive Reuse and Single-Use Residential Incentive Amendment (PZ250041)

Planning Staff Tiffany Antel presented a text amendment authorizing new affordable housing incentives tied to Flagstaff's $20 million Proposition 442 general obligation bond for rental and home ownership opportunities. The amendment creates two new definitions—adaptive reuse (repurposing an existing building to a new use while preserving existing elements) and single-use residential (100% residential development in commercial zones)—and removes conditional use permit requirements for qualifying affordable housing projects.

Key Provisions

Single-Use Residential in Commercial Zones: If 20% of housing units meet 80% of area median income (AMI), the CUP requirement is waived. This targets new construction in commercial areas, which Antel noted often avoid conflicts with single-family neighborhoods and reduce trip distances for daily needs.

Adaptive Reuse Incentives: For buildings at least 15 years old with additions not exceeding 25% of existing footprint, qualifying projects are exempt from:

• Parking requirements
• Site planning and design standards
• Landscaping standards
• Common open space requirements
• Architectural design standards

Non-Residential Adaptive Reuse Parking Reduction: Commercial buildings undergoing use changes (retail to restaurant, for example) are not required to upgrade parking if the building is under 5,000 square feet, has no addition exceeding 50%, and on-street parking exists within a quarter mile.

Commissioner Questions on Enforcement

Commissioner Ian Sharp raised concerns about enforcing income thresholds over time. Housing Planning Manager Jennifer Michaelelsson explained that bond-funded projects require loan documents with reporting requirements, and tenants' income must be verified annually against an 80% AMI threshold at lease signing. Projects may allow tenants to earn up to 100% AMI while remaining as existing occupants, but new tenants must re-qualify at 80% AMI.

"So, we would tracking them that way... they would be sending us annual reports with the tenant um income information for each of those units." — Jennifer Michaelelsson, Housing Planning Manager

Commissioner Norton also flagged the existing exemption for 100% affordable HOH projects (moving a conditional use permit exemption from the definitions section to the affordable housing incentives section). Antel confirmed this provision pre-dated the current amendment, having been added in 2022.

Commissioner Joshua Maher questioned the 15-year age benchmark for adaptive reuse qualification. Antel noted that comparable codes average 15–25 years, and the lower threshold was chosen to encourage housing creation without incentivizing new construction deliberately designed to avoid standards.

The Commission voted unanimously to recommend approval to City Council. Commissioner CJ Lukey made the motion, seconded by Commissioner Christine Shehy.

High Occupancy Housing Code Update (PZ25-000028)

Tiffany Antel presented the second major amendment, detaching zoning code provisions from the regional plan's evolving land-use categories and simplifying HOH density tables. The amendment removes the requirement for alternative floor plans in HOH projects, eliminates CUP location requirements within activity centers, and removes size limitations tied to specific activity centers.

Key Changes

Density Calculation: Modifies the definition to require both bedroom density and unit density thresholds to trigger HOH (changing the existing "or" to "and"), which staff noted would have prevented several of the evening's single-family cases from triggering the CUP requirement in the first place.

Conformance Analysis: All HOH projects must now demonstrate conformance with the regional plan and any applicable neighborhood or specific plan, providing the Commission leverage to deny or condition projects that conflict with adopted area plans (e.g., Southside Plan, Plaza Vieja).

Administrative Changes: Removes requirements for alternative floor plans, eliminates footprint limitations tied to historic activity centers (a designation being eliminated in the regional plan update), and updates waste management and crime-free housing standards.

Statutory Context and Commissioner Concerns

Before discussion, Antel pivoted to address potential future amendments. She explained that state preemption of the middle housing bill (requiring uniform treatment of up to four units as single-family) necessitates separate future amendments to determine whether to remove the single-family HOH CUP requirement or merge HOH and middle housing into one land use category.

"I know I gave you two drafts. Um we would move my request tonight is um only on the draft that keeps in the conditional use permit at this point in time." — Tiffany Antel, Planning Staff

Commissioner Norton raised a critical concern: whether removal of the CUP requirement for 100% affordable HOH projects creates exposure to Proposition 207 claims (property owner compensation demands for regulatory taking). Antel acknowledged the risk but noted that the exemption already existed in the 2022 adoption, and that any future amendment carries potential 207 exposure. She emphasized the exemption's scope: it applies only to projects qualifying as 100% affordable, a narrow category.

"If we remove the requirement for CU and then what if we have some unintended consequences and that gets put back in, it just opens up another raft or opportunity window for more 207 claims." — Commissioner Mary Norton

"That's an issue I think with any code amendment that we face is you know if we were to undo it then and we decided later on we wanted to go back but um there are other components so that is not the only aspect of that zoning code amendment was fairly significant." — Tiffany Antel

The Commission voted unanimously to recommend approval to City Council. Commissioner Shehy made the motion, seconded by Commissioner Norton.

Flagstaff Regional Land Use Plan 2045 Citizen Review Session

The second half of the meeting pivoted to a 90-minute presentation and discussion of the draft Flagstaff Regional Land Use Plan 2045, led by Comprehensive Planning Manager Sarah Dector. This was not a formal hearing but a citizen review session designed to prepare the public and Commission for two public hearings scheduled for September 10 (at the Aquiplex, 4–7:30 p.m.) and September 24 (City Hall).

Scale of the Plan Update

The plan consolidates the current 97 goals and 490 policies into 23 goals and 87 policies. It was developed jointly with Coconino County and incorporates over 2,000 public comments from a 60-day review period (October–December 2024). The document is approximately 200 pages of substantive text, presented as an interactive web-based document with hyperlinked definitions, clickable table of contents, and embedded maps. The full file is 500 megabytes, reflecting its complexity and accessibility features.

Process History

The plan underwent a four-phase development process:

1. Phase One (Listening): Year-long engagement including weekly webinars (six months), visioning workshops across the community, a technical advisory group, 13 "Face the Future" gamified scenario-planning workshops, two online surveys, and open houses. At least 800 people participated (not counting advisory committee members).

2. Phase Two (Scenario Planning): Collaborative community workshops modeling growth outcomes under three scenarios (flat/declining, modest growth, and accelerated growth).

3. Phase Three (Advisory Committee & Legal Review): A 15-member regional plan committee (convened by City Council and Coconino County Manager nominations) reviewed the plan chapter-by-chapter, met 15 times over eight months, and provided critical feedback. Staff conducted extensive legal review to identify unintended consequences and conflicting policies.

4. Phase Four (Current): Public hearings (September 10, 24) followed by City Council special meeting (October 9).

Dector emphasized that the 2020 census revealed the first decline in Flagstaff's growth trajectory in 50 years, requiring the plan to address three scenarios: flat growth, modest growth, or accelerated growth. She stated:

"The prior to the 2020 census, when you saw this graph... it would be grow a little, grow medium, grow a lot. That's not the future this plan is written for." — Sarah Dector, Comprehensive Planning Manager

Key Changes from 60-Day Public Review

Plan Clarity: Two-thirds of public comment focused on readability and clarity. The draft was reorganized from chapter-based structure to a web-native format with hyperlinked definitions and non-continuous page numbering per chapter (to allow updates without reprinting the entire document).

Development Patterns & Goals: Completely rewritten; the original language "just didn't land" and required substantial revision.

Future Growth Illustration (Land Use Map): Consolidated suburban neighborhood categories from two density tiers to one; clarified corridor locations within suburban neighborhoods; adjusted the John Wesley Powell, Southside, Milton-Woodlands Village areas; converted some employment districts to residential (except the Fort Tuthill hospital site, which retains an adopted specific plan designation).

Findings of Conformance Process: Tiered approach replacing blanket 500+ policy analysis. Projects conforming to land use categories and basic guidelines face streamlined review; projects requiring plan amendments must demonstrate they "substantially further" at least two of six core priorities.

Urban Growth Boundary Flexibility: Reduced flexibility for well failures and small property owner water service extension to address public concerns about sprawl.

Administrative Amendment Categories: Six new categories (up from zero) for non-substantive updates: formatting/typos, URL updates, mapping corrections, adopted park/open space additions, zoning category name changes, and factual updates to informational maps.

Core Priorities & Policy Organization

The plan identifies two non-negotiable core priorities:

1. Housing Attainability and Equity
2. Climate Action

Four complementary priorities support these:

• A Healthy Economy
• A Walkable, Mixed-Use Community
• Conservation of Natural & Cultural Resources
• Resilient Services & Facilities

Policy language ties parking, transit, multifamily housing, and economic opportunity directly to these priorities. Commissioner Norton asked whether the housing and climate emergencies declared by City Council carry statutory weight. Dector clarified through Housing Planning Manager Jennifer Michaelelsson and Climate Action Section Director Jenny Neman that the emergencies are not statutory but represent community-declared crises. Michaelelsson noted:

"The emergency declaration particularly from the climate side which I'm more familiar with um is really to say we have a crisis in our community and we are responding to it." — Jenny Neman, Climate Action Section Director

Specific Plan Conflicts & Rescission

Existing specific plans (Southside, Plaza Vieja, McMill and Mesa Village, Woodlands Village, John Wesley Powell area, Northern Arizona Hospital area) may conflict with the new regional plan. Dector proposed rescinding the Woodlands Village Specific Plan (adopted 1998, now complete), as its outdated conference-facility restrictions conflict with current code and serve no ongoing purpose. Other plans will be reviewed; those adopted by ordinance (McMillan Mesa Village, Northern Arizona Hospital area) cannot be overridden by the regional plan (which is a resolution).

Major & Minor Plan Amendment Restructure

The plan reorganizes major/minor amendment categories based on urban growth boundary location and intensity changes, rather than activity center location:

• Inside UGB, increasing density/intensity: Minor amendment (preferred outcome)
• Inside UGB, decreasing density/intensity: Major amendment (resource-inefficient)
• Outside UGB, increasing utilities/density: Major amendment (sprawl concern)
• UGB expansion + utilities extension: Major amendment (always)
• Corridors lacking arterial/collector access: Major amendment (connectivity concern)
• Park/open space/working landscape deletion: Major amendment (always)
• Deletion (or de facto deletion) of goals/policies: Major amendment

Major amendments still require sequential processing (plan amendment, then zoning amendment)—Flagstaff has not allowed concurrent application since the 1990s, though Commissioner Christine Shehy noted this creates affordability friction and that other jurisdictions allow concurrency. Dector deferred this to a separate code update (Title 11), acknowledging the issue but noting it falls outside the regional plan's scope.

Findings of Conformance Flowchart

Dector presented a tiered approach: projects conforming to land use category, basic guidelines (12–15 site-planning standards applicable across all categories), and category-specific guidelines proceed through standard review. Projects requiring plan amendments must demonstrate conformance with transportation framework maps and substantially further at least two of the six core priorities. Dector stressed:

"There's substantially further is actually the language in the state statute. It doesn't say you have to match everything. It says you've got to substantially further a part of the plan." — Sarah Dector

Public Comment Integration & Outstanding Issues

Public comments addressed:

• Plan Clarity: Maps needed accessibility for color-blind users; text needed simplification
• Carbon Neutrality: How climate action integrates into development review
• Density & Character: Confusion about density calculation and neighborhood character impacts
• Parking: Strong support for reduced minimums and winter parking flexibility
• Natural Resources & Food Systems: Expanded discussion needed
• Adaptive Reuse & Flexibility: Endorsed by the public

Russell Randall, speaking for Barrier-Free Flagstaff and the Northern Arizona Community Practice Transition Team, praised the draft's improved accessibility language but flagged:

"Something we would like to see more actually is there's more mention of accessibility and inclusion in the goals and practice are policies part of the draft than in the action items and we would like to see probably that uh reversed or at least balanced out a little bit more." — Russell Randall, Barrier-Free Flagstaff

Randall also noted inaccessible color-coded maps and absent disability discussion in Chapter 5 (social and economic systems).

Robert Booth raised water sustainability concerns, citing a 2012 water study and the paradox that Flagstaff residents face water restrictions while apartment complex residents do not. He called for an updated sustainability study accounting for climate change and population growth.

Dector responded that online tools (e.g., colorblind-accessible web maps) could be created post-adoption to supplement the printed/ballot version, and that the parking lot tracking system would ensure substantive edits are documented for City Council review.

Hearing Process & "Parking Lot" System

To avoid the 2013 regional plan's 10-month continuation cycle, Dector proposed a "parking lot" (later clarified as a "holding zone" due to Commissioner Mandino's observation that parking lots cost money) to track proposed edits. Commissioners may direct staff to add items to the list; before voting, the Commission reviews the consolidated list and votes on each change. Staff prepares track-changes documents for City Council.

The September 10 hearing at the Aquiplex runs 4–7:30 p.m. (venue closure time is hard stop). September 24 continues at City Hall with no time limit. If necessary, a September 8 meeting or a second continuation can extend deliberations, though Dector urged efficiency to avoid delaying City Council's October 9 special meeting.

Commissioners were urged to submit written comments to [email address for public hearings], which goes to all commissioners, staff, and council—avoiding open-meeting-law quorum issues. Commissioners should not use this email to communicate with each other; internal edits should go to staff and be verbally proposed in public.

Duration & Attendance

The meeting lasted from approximately 2 p.m. to 6:43 p.m. (total ~4.7 hours). Commissioners Mary Norton noted she would be out of town September 10; Commissioner Norton also flagged that September 24 coincides with a Jewish holiday. The Aquiplex hearing is September 10 at 4 p.m. (staff setup at 3 p.m., early arrival requested for sound check). City Council will hold a special meeting October 9 to consider adoption.

Controversies & Context

State Preemption & Housing: Dector noted that Arizona state legislation preempted local inclusionary zoning authority, preventing Flagstaff from mandating affordable units. She inserted a "placeholder policy" allowing future amendments if state law changes. Commissioner Shehy urged city leadership to lobby for increased local control (noting 75,000-person threshold inadvertently includes Flagstaff when 100,000 would exempt it).

Middle Housing Bill Ripple: Staff must separately address how the state's middle housing bill (requiring four-unit clusters to be treated as single-family) interacts with HOH code. Antel deferred single-family HOH CUP changes pending middle housing amendment drafting, expected back before Commission in ~one month.

Prop 207 Claims: Commissioner Norton raised the specter of property owner compensation claims if the CUP requirement for 100% affordable HOH is removed then reinstated. Antel acknowledged the risk but noted the exemption already exists, and any amendment invites potential claims—a cost of legislative adjustment.

Text-Map Conflicts: Commissioner Shehy surfaced a prior regional plan amendment where map and text conflicted, creating litigation. She requested explicit language that text overrides maps in case of conflict. Dector agreed to add this to the parking lot.

Next Steps & Continuance

• September 10, 4–7:30 p.m.: Public hearing at the Aquiplex (Flagstaff Aquatic Center). Commissioners asked to arrive ~3 p.m. for sound check.
• September 24, 4 p.m.: Continuation at City Hall (no time limit).
• September 8 (optional): One additional P&Z meeting slot available if needed for parking lot finalization.
• October 9: City Council special meeting (~6 hours) for adoption discussion and ballot referral decision.
• Spring 2026 (anticipated): Voter ratification ballot.

The plan currently incorporates 2,000+ public comments and will be refined through the Commission's edits before presentation to voters.