Last year a group of dedicated professionals, city planners, engineers, former county officials and others became concerned about zoning and land use issues in Knox County when the then new mayor proposed to remove key provisions of the county’s Growth Plan.
It was commonly believed the mayor was being pressured by a group of aggressive developers and that he might not fully understand the complex set of protections and rules governing development nor the consequences of removing the vital protections for taxpayers and property owners.
The group believed that if the mayor’s proposal were successful a chaotic, wild wild west of unplanned, unregulated development would occur. The consequences to the county would be irreversible. To help the mayor avoid a bad mistake, the volunteers donated hundreds of hours researching, documenting and outlining a better path. They presented the mayor a fair, cogent, alternative plan. The mayor continued to pursue elimination of the key restrictions of the Growth Plan. There is now proposed legislation pending in Nashville to completely eliminate Knox County’s Growth Plan along with those across the state.
Below is the volunteer group’s plan for updating and revising the Knox County Growth Plan.
ETCPA Position on Proposed Growth Policy Plan Amendment
April 18, 2019
East Tennessee Community Planning Alliance (“ETCPA”) is a coalition of citizens and community group representatives that advocate effective planning for future growth in Knox County, Tennessee. We support thoughtful planning processes that take into account the
concerns of all stakeholders, the cumulative impacts of development, and the need for fiscally-responsible plans for future growth. If adopted, the proposed Growth Policy Plan (“GPP”) amendment1 would:
1. Transfer control of zones allowed in the Rural Area to the Sector Plans;
2. Remove density limits for Planned Residential; and
3. Eliminate requirements for cumulative traffic impact analysis.
ETCPA is extremely concerned about delegating long-term planning to the Sector Plan process, a process that sees amendments approved almost monthly at MPC and County Commission. ETCPA supports the decision to reconvene the Growth Plan Coordinating Committee (“GPCC”) but recommends the following approach:
● Alter the proposed amendment. Reinstate the Plan without deleting sections 3.2 – 3.6. This maintains the status quo and eliminates the confusing legal status of the mandatory and optional portions of the Plan.
● Update the 1999 Land Capability Analysis2 with current data . This report provides information on projected population growth, development and economic activity, agricultural and constrained land, and projected land usage requirements. It is woefully out-of-date for current planning purposes.
● Develop replacements for the lengthy vision and aspirational sections of the GPP. In particular, streamline the mandatory policies, especially in light of Tennessee annexation law changes.
● Require fiscal impact analysis . For rezonings and concept plans filed in the Rural Area, require a fiscal impact analysis to determine the cost of extending transportation, utilities, schools, parks, and other services to that area.
● Assess the current PGA and Rural Area boundaries and update if appropriate.
● Provide robust protections for the Rural Area to protect agriculture, set aside land for future economic development, while concentrating current economic, commercial, and residential development into designated Planned Growth (“PGA”) areas.
ETCPA Position Paper on Proposed Growth Policy Plan Amendment – Page 1
● Amend and adopt an updated and streamlined GPP, and then update and streamline the Knoxville – Knox County General Plan.
● Revisit the Growth Policy Plan every three to five (3-5) years. We believe the updated Growth Plan, if properly done, will:
● Provide certainty to the market, developers, businesses, government, and citizens. This allows developers to focus on realistic projects, while residents can focus on building communities and their own businesses, instead of fighting developers and land speculators. Strong planning and zoning helps businesses and residents feel confident that their investment will be protected – with other high quality developments, and with infrastructure and community amenities (schools, parks) that are not oversubscribed.
● Encourage business development instead of real estate development. Real estate development converts our remaining land resources into profits for the developer, without regard to the long-term viability of the area for the citizens.
● Protect Knox County soils and agriculture, which – as noted below – contribute $3.0 billion a year in economic impact. Once land is developed, it won’t return to agriculture.
● Stabilize the county’s financial model by focusing growth dollars (transportation, schools, emergency services, stormwater) in higher density, planned growth area projects and containing expenditure growth in the Rural Area.
● Increase affordable housing by concentrating all housing closer to places of employment, which results in lower commuting costs for residents.
Why is the Growth Policy Plan Important?
The GPP provides a high level, 20-year direction about where development is encouraged, and what constraints are placed on areas we consciously set-aside for forest, agriculture, wilderness, and potentially future growth. It gives developers, planners, government officials, and citizens a level of certainty. When the rules and framework are clearly laid out and followed, markets perform more predictably (and less speculatively). The GPP is the only document and process that brings together many key stakeholders across
the county: Knox County government, City of Knoxville, Town of Farragut, major utility providers, schools, economic development (Chamber of Commerce), agriculture and environment (Soil Conservation District), and citizens. It provides the framework for development that all of the other, more detailed plans can leverage – for example, utility, school, and transportation planning. The plan is based on detailed analysis, not the latest political leanings of each legislative body. But, it is an expression of local control – all of the Coordinating Committee members are local citizens, and the plan’s approval is through the local legislative bodies. ETCPA Position Paper on Proposed Growth Policy Plan Amendment – Page 2
A robust growth plan aids both economic development and conservative fiscal planning. Businesses and employers considering where to do business prefer communities with strong, effective planning that offers them predictability needed for their cost models, and provides quality of life that attracts employees. Conservative fiscal planning by local government officials is only possible if they can anticipate where and when new or expanded public services will be needed.
Problems and Potential Solutions
Our GPP has not worked for several reasons:
1. It is a 20 year planning document, adopted in 2001, and has never been updated.
2. The GPP provisions for the Rural Area don’t encourage conservation. Allowing one du/acre in Agricultural-zoned land simply creates large-lot residential sprawl. As for specifying agricultural conservation – there is only one parcel, of 131 acres, in the entire county with a Sector Plan designation of “Agricultural Conservation”, and no property is yet zoned “Rural Preservation.”
3. It contains many policy and vision statements that are duplicated in the General Plan, thus making it unwieldy to update either document. (To avoid conflict, you have to make updates in two places, using two different amendment processes.) The Proposed Amendment, if enacted, will do more harm than good. It will:
1. Rely on the General Plan and Sector Plans, which are primarily vision and guidance documents. The plans contain numerous recommendations, but very few “shall” and “must” statements that MPC and county commission must comply with.
2. Place full control of the allowed zones, and density, of the Rural Area in the hands of the County Commission through the Sector Plan process. This leaves out key stakeholders, such as schools and utilities. Plan amendments can occur any month, increasing the involvement level of any parties that wish to participate in long-range planning.
3. Create uncertainty. Developers and businesses abhor uncertainty and instability. Rural area development policies can be changed at the whim of an applicant and the County Commission. This politicizes a decision-making process and creates instability for government and utility budget planning.
What’s this Really About?
Scattershot Development is Expensive for Knox County Government
Development in Knox County is leapfrogging; it is not meshing with planned improvements of transportation, utilities, schools, emergency services, and public parks. Scattershot development in the Rural Area makes new and heavy demands on local government and
utilities, straining their budgets and competing for funding with projects in the Planned Growth Area. Taxpayers and ratepayers – not the developer – bear the infrastructure costs for new or enlarged roads, schools, emergency services, parks, and utilities.
ETCPA Position Paper on Proposed Growth Policy Plan Amendment – Page 3
The development pressure in the Rural Area comes from single family residential development, not commercial enterprises that bring jobs, higher property tax revenue, and additional sales tax revenue. Today the county is operating a real estate development model rather than an economic development model. The real estate development model consumes large swaths of land and actually works against business development – it consumes land that could be used by revenue-producing agriculture or reserved for future economic development. Reusing existing land, buildings, and infrastructure is more cost efficient. While homebuilders may market their ability to build houses less expensively at higher density, this doesn’t create affordable housing. It’s actually less affordable:
– For the residents: who pay more in increased transportation costs (time, fuel).
– For the government, schools, and utilities: which actually end up spending more for each person in a single family residence than it receives from property and sales tax revenue.
Related to affordability – the cost of transportation. According to the MPC 2017 Workforce Housing Report by MPC , most county residents spend more than the 3 recommended 15% of income on transportation costs. More than 95% of residents living in the Northeast Sector commute to a place of work outside that sector4, yet this is an area the homebuilders are looking to develop in the next ten (10) years.
4 2015 Northeast County Sector Plan, page 1 , https://archive.knoxmpc.org/northeastcounty/necounty.pdf
ETCPA Position Paper on Proposed Growth Policy Plan Amendment – Page 4
Developing in the Rural Area also reduces land available for agriculture. The 2015 UT Extension Service analysis estimated the agricultural economic impact in Knox County was $1.9 billion, and with multiplier effects, a total of $3.0 billion . During the same 5 period, there were 4,940 workers directly employed in agriculture in Knox County, and with multiplier effects, an estimated 12,807 jobs. Since 2001, 3,208 acres of land have been rezoned to non-Agricultural uses in the Rural Area. 1,210 acres of that were soils that are Prime Farmland or Locally Important – soils that are permanently lost. In the same time period, in the Planned Growth Area, another 3,164 acres of prime farmland and locally important soils were rezoned away from Ag.
The proposed amendment can be modified to reaffirm and reinstate the Growth Plan without modifying sections 3.2-3.6. After this amendment is approved, then there is an opportunity to thoughtfully revise and update the Growth Plan. A Growth Plan, regularly updated, with input from all governments, utilities, schools, and the community will help:
● Provide certainty to the budgets for governments, schools, and utilities;
● Shift our growth from developing real estate to developing businesses and our economy;
● Protect Knox County soils and agriculture; and
● Increase affordable housing by concentrating all housing closer to places of
employment, which results in lower commuting costs for residents.
ETCPA Position Paper on Proposed Growth Policy Plan Amendment – Page 5