Staff recommends the City Council hold a public hearing on the annexation. Upon completion of the hearing, staff recommends the City Council annex the petitioned property with the recommended conditions of approval. 

Larson Family Properties, LLC is requesting to annex approx. 53 acres near the intersection of Shiloh and Zoo Drive.  The property is currently used for farming activities.  As part of the annexation, the property will be rezoned to allow for the development of residential and commercial lots on the land they are proposing to annex. The annexation request meets the applicable criteria for annexation review as outlined in the staff report.

Sanbell, on behalf of Larson Family Properties LLC, submitted a petition to annex land using the provisions of Section 7-2-4600, MCA. The property is located west of the intersection / roundabout of Shiloh Road and Zoo Drive. It is legally described as Tract D of Amended Tract 1-A-2 of COS 1100, Tract 2-B of Amended Plat of Tract 2, COS 1100, and Tract 2-A-1 of Amended Tract 2-A of Amended Tract 2, COS 1100, S22, T01 S, R25 E. Said annexation boundary is approximately 53 acres gross including adjacent rights-of-way.  

The property is currently zoned Ag (Agriculture), NMU (Neighborhood Mixed Use), and RR1 (Rural Residential 1). These zoning districts are county zones. The applicant is undergoing a concurrent zone change to Corridor Mixed Use 1 (CMU1), Mixed Residential 1 (NX1), First Neighborhood Residential (N1) and Parks and Open Space 1 (P1) to allow for future commercial and residential development.

It is the City’s custom to have staff prepare a brief analysis of predicted impacts to services and facilities. Staff finds the proposed annexation complies with the adopted Annexation Policy criteria as follows:

1. The area must be located within Zone 1 or Zone 3 of the Limits of Annexation Map.
   • The area is within Zone 1.
2. The City must be able provide adequate city services at a cost acceptable to the City within a time period mutually agreed to by the property owners requesting annexation and the City.
   • The properties are already adjacent to a development within city limits. Connections to existing services will be addressed via the Annexation Agreement.
3. Existing or proposed public improvements within the area to be annexed must meet City standards.
   • The properties are already adjacent to a developed subdivision within city limits. Connections to existing services will be addressed via the Annexation Agreement.
4.  All property owners within the area to be annexed must sign a Waiver of Right to Protest the creation of Special Improvement Districts.
   •  A Waiver of Right to Protest the Creation of Special Improvement Districts is included with the Annexation Agreement.
5. All residential property owners within the area to be annexed must create or join an existing park maintenance district.
   • There are no current park maintenance districts in the area. Any park maintenance district would be a new district.
6. Residential densities planned for development within the area to be annexed must meet an overall average minimum density of primary dwelling units per acre as per the current City of Billings Growth Policy or similar planning documents.
   • The annexation will result in the creation of multi-family, single family, and duplex density with the lots being created. The multi-family density will have some similarities with the density of the development to the north. The single family and duplex density will be similar to the lower density of some county development to the southwest.
7. The proposed land use within the area to be annexed must conform to the goals of the adopted City of Billings Growth Policy.
   • Strong Neighborhoods (livable, safe, sociable and resilient neighborhoods): Neighborhoods that are safe and attractive and provide essential services are much desired.
   • Home Base (healthy, safe and diverse housing options): Planning and construction of interconnected sidewalks and trails are important to the economy and livability of Billings.
   • Essential Investments (relating public and private expenditures to public values): Planning and construction of safe and affordable interconnected sidewalks and trails are important to the economy and livability of Billings.

Departmental Response: City and County Departments were given the opportunity to comment on this annexation. City departments responded favorably, and responses are provided below.

• Water and Sanitary Sewer: Public water and sanitary sewer service is available to the property proposed for annexation. The Developer will be responsible for connecting to the sanitary sewer mains and a water main in Shiloh Road along the frontage of the above-described property.
• Storm water: Any development will be compliant with the adopted Stormwater Management Manual. 
• Transportation: The developed land will be accessed from Shiloh Road. The main access will be from the Shiloh Road and Zoo Drive roundabout.  The Public Right-of-way along Shiloh Road north of the roundabout is already dedicated to the City of Billings. Right-of-way south of the roundabout is controlled by MDT.  
• Fire Stations: The Billings Fire Department currently serves the subject property through the Billings Urban Fire Service Area agreement.  The Billings Fire Department will continue to serve the property upon annexation.  As this and additional annexations are built out, additional fire department resources will be needed to meet and maintain our high level of service due to the increased call volume and burden on our department these annexations create.  The fire station serving this area is Station #7, approximately 6 road miles to the subject property
• Parks: No parkland or trails will be required as part of this annexation.
• School facilities: School District #2 did not raise any special requests or concerns during their review of this proposal. 

General City Services: These are the City services that are provided to all residents and businesses in the City, such as police and fire protection, street and storm drain maintenance, and garbage collection and disposal. The service providers that responded did not object to the annexation of this property. However, the Fire Department in its comments above did note its concerns as additional property is annexed into the City.

• Transit: The annexed area is not directly serviced by a MET Route. Route 23, South West end "Circulator" does go past the property with a stop, 2312, at Pierce Parkway and Shiloh Road. This stop is approximately 438 feet from the south-east corner of the proposed annexation property.
• Police: This proposed development is adjacent to established city limits and will not require an adjustment in schedules or staffing at this time. There is sufficient ingress/egress to the area. Despite recent passage of a safety levy, continued annexation and development will affect our ability to deliver service without commensurate resources.
• Public Utilities: The Public Works-- Distribution and Collection Division had no concerns with the annexation request.
• Public Works -Street and Traffic Division: The Street and Traffic Division stated that it has no concerns with serving the property.
• Public Works-Solid Waste: The Solid Waste Division had no concerns with annexing the property, but pointed out that State Law allows the property owner to choose what garbage hauler may service the property after it is in the City.  
• Ambulance Service: The City does not provide ambulance service; however, it does dictate the level of service provided by American Medical Response (AMR). By City ordinance, 90% of ambulance calls must be answered within 8 minutes. Depending on factors at any given time such as traffic and congestion, this property may be within the area of acceptable response time.
• Legal and Finance: General Fund services, such as the Legal and Finance Departments should not be negatively impacted by this annexation.
• Other Departments: City/County services, including Library, Planning, and Environmental Health, are only slightly affected by the annexation since they will continue to serve the property whether it is in the City or the County. The Planning Division staff supports the annexation because it is consistent with the Limits of Annexation map and the criteria of the annexation policy have been met. 

The Planning Division staff supports the annexation because it is consistent with the Limits of Annexation map and the criteria of the annexation policy have been met. Further, coordination with other departments does not raise concerns that cannot be mitigated. These decisions have a cumulative effect therefore, City Council is being provided with a recommendation of approval.
 

This application has no impact on the Planning Division Budget.

Annexation by petition does not require notification of adjoining landowners; however, it does require that the City Council conduct a public hearing, advertise the hearing, and post the property with information on the annexation petition and public hearing. Notice of the public hearing was posted on the property and was advertised in the Yellowstone County News.

The City Council may

• Approve,
• Conditionally approve or
• Deny the petition for annexation.

Denial of the petition will mean the City Council cannot consider other agenda items related to this property regarding the development agreement, ward boundary ordinance, and zone change. On March 16, 2026, the annexation petition was submitted to the Planning Division by the owner's agent.  On April 27, 2026, the City Council is scheduled to take action on the petition.