Land Availability and Suitability Study and Code Analysis Project (LASS+CAP) Project Update and Discussion
 

Project Overview:

Flagstaff’s growth in population, coupled with a housing crisis that has limited housing choice and affordability and a climate crisis that is disrupting weather patterns and threatening communities, has exemplified the need to better plan and coordinate internally and externally.  The City's housing emergency, as well as the increased threats of wildfire, flooding, drought, and other climate impacts, has presented a vital need for Flagstaff to better understand the extent of land that is available in Flagstaff for housing development, the barriers that exist to developing new housing, and the changes that can be made to the City’s development code and processes to encourage and increase the supply of new housing while recognizing the City's Carbon Neutrality Plan goals.  This work supports several City housing and climate goals in the City’s 10-Year Housing Plan, Carbon Neutrality Plan, and other documents while acknowledging the tensions between other community assets and values.

The Land Availability and Suitability Study and Code Analysis Project (LASS+CAP) is a multi-pronged initiative to address critical long-term planning and resilience needs. There are two components to this project: the Land Availability and Suitability Study (LASS) and the Code Analysis Project (CAP).

1. The purpose of the LASS is to understand what land is available within the Flagstaff city limits and peripheral areas for development and redevelopment/infill and the barriers that exist.
2. The Code analysis portion of the project will analyze City codes applied to development projects and will identify what works well and identify the barriers to meeting the City's housing and climate goals and policies.

The LASS and the CAP are being completed concurrently. The LASS is a land inventory study to identify what lands are left to develop or redevelop as residential and identifying the opportunities and/or barriers for their development or redevelopment. While the LASS includes both privately and publicly owned lands, the study does not make commitments or obligations for any of the parcels identified, rather this is a data snapshot to understand how much land is potentially available to meet our residential needs. Any private property owner whose property has been included in the inventory is welcome to reach out to staff to discuss the project in more detail. The CAP is a code analysis looking at all development codes and processes to ensure all are working towards our housing and sustainability goals. While being done concurrently, the LASS is a standalone document representing technical data from a point in time that will inform the CAP project, as well as the Regional Plan Update, regarding scenario planning and policy setting. 

This effort is being completed in partnership between Community Development's Planning and Development Services and Housing Sections, the Sustainability Division, and the Transportation Engineering Section. It will provide a much-needed base for high-level coordination between numerous other City Divisions/Sections such as Fire, Building Safety, Economic Vitality, Water Services, PROSE, in addition to the primary City partners, and Mountain Line.

Land Availability and Suitability Study
The draft LASS report was completed using the following methodology:

• Establishing a preliminary buildable land inventory for the City of Flagstaff and peripheral areas in the project’s study area;
• Determining which areas are buildable by applying screening criteria to the study area based on environmental constraints; and
• Identifying and assessing “opportunity sites” from the resulting net buildable land inventory. These are sites that present unique opportunities for the creation of housing.

Through the Land Availability and Suitability Study, the consultant has established the following key findings about Flagstaff’s land availability:

• Flagstaff and the peripheral areas that make up the LASS area contain approximately 8,125 acres of vacant land spread across 2,242 parcels. Of this land area, approximately 6,735 acres are residentially zoned.
• The study area also contains approximately 5,399 acres of underutilized land spread across 1,822 parcels. These lands contain minimal structures that have a low enough improvement Full Cash Value (FCV) to suggest that economic forces could encourage their redevelopment for a greater or higher value use, such as housing.
• In total, the study area contains approximately 7,062 acres of vacant buildable land and approximately 4,865 acres of underutilized buildable land. These lands represent the lands most likely to develop or redevelop in the future.
• Approximately 13% of the vacant land within the study area is environmentally constrained by stream corridors, wetlands, steep slopes, and floodplain or floodways. These lands may not be conducive to development or redevelopment, including for housing.
• The most common environmental constraints in Flagstaff are steep slopes and floodplains and floodways. This analysis considered steep slopes as any slope 25% or greater, which impacted nearly 7% of the study area’s land. However, Flagstaff currently regulates development on slopes 17% or steeper through the Resource Protection Overlay, which represents a significant barrier to housing development on sites that may be able to support development. As the LASS+CAP project team continues to evaluate code section modifications that, if implemented, could result in greater residential yield, the steep slope provisions of the Resource Protection Overlay may offer such an opportunity. 
• Floodplain and floodway areas impact over 4% of the study area land. It is likely that this number will be reduced through the eventual construction of the Rio de Flag Flood Control Project. Nonetheless, floodplain and floodway within Flagstaff currently presents a significant challenge to the development of housing in the study area’s vacant parcels.

In general, Flagstaff has a significant amount of buildable land within its city limits and in its immediate periphery that can be used for the development of housing. However, much of it will require being rezoned to a higher density zoning designation and is lacking the necessary infrastructure to support higher density development.

It is expected that this analysis will help inform both the CAP and the Regional Plan update by identifying the areas that could most benefit from additional density and infill, among other changes that could positively impact housing yield. For example, the CAP may recommend zoning code or development review process changes that impact the density allowed in different zoning districts or when Water Sewer Impact Analyses (WSIA) or Traffic Impact Analyses (TIA) are required. Some observations of note include:

• Currently, only individual Opportunity Site redevelopment on the smallest of downtown or Southside sites may not trigger WSIAs, and even then, this only applies if existing infrastructure appears to be sufficient to meet new development needs. Any larger developments will all require WSIAs.
• Currently, most of the higher opportunity level sites will require TIAs. Developers in the community have noted that this can be a lengthy and expensive process with difficult-to-predict mitigation. Changes to how the City manages traffic information and TIA processes could improve the likelihood and affordability of more significant housing development projects.
• Some of the largest sites that may become entirely new development areas tend to be zoned Rural or Estate Residential, which leads to very spread-out development that only serves high income groups. Whether these sites are currently owned by other public entities or private owners, the next steps in Table 25 of the LASS report recommend the City investigate ways to help encourage at least some areas within these large sites have higher density.

The draft LASS document will help provide specific locations and examples of where significant housing opportunities exist and therefore serves as a resource for considering when, where and how future code amendments, zone changes, collaborative development planning and master planning efforts will make the most impact in the City.

Code Analysis Project – Code Diagnostic  
The Code Analysis Project is a multi-phase project that will identify code barriers, provide opportunities to remove barriers, and recommend code revisions that will support the achievement of the Flagstaff Carbon Neutrality Plan and Housing Plan goals. The Project will be completed through three deliverables including a code diagnosis, exploration of concept code changes, and then a final report with recommendations. All phases of this project will be presented to supporting Commissions (Planning & Zoning, Housing, Sustainability, and Transportation). This three-prong approach will allow staff in conjunction with City Council to identify smaller code changes that may be processed prior to the final recommendations.  The draft Code Diagnostic is the first deliverable in the Code Analysis Project which is attached for Commission and Council review. 

The scope of the Code diagnosis, concepts, and recommendations addresses the following codes and any other identified affected codes, standards, policies, or plans as identified by the City:

• Fire Code
• Engineering Design Standards and Specifications for New Infrastructure
• Zoning Code
• General Plans and Subdivisions
• Public Ways and Property
• Building Regulations
• Transportation Impact Analysis Manual
• Incentive Policy for Affordable Housing
   

Additionally, an Equity and Displacement Vulnerability Assessment was conducted to assist with identifying code barriers.  The consultants prepared a demographic and spatial analysis of the city to assess which neighborhoods are more vulnerable to the potential negative impacts of Code changes in accelerating gentrification and residential displacement.

Each code barrier was reviewed as follows:

Relevant Goal/Policy: Identify all of the relevant goals/policies that the code provision presents a barrier to meeting.

Magnitude and Impacts: Evaluate the magnitude of the barrier and discuss the specific impact it has on the ability of the City to meet its policy goals. The Consultant Team will coordinate to use a consistent method for evaluating the magnitude of a barrier. The magnitude of the barrier may vary depending on the policy goal. If so, that variation will be identified. The barriers were graded on the following scale:

• Critical Barrier: Code provisions that render it physically or economically infeasible to develop a project that contributes to the City’s housing and/or climate goals. These code provisions generally are barriers independent of other standards or requirements and apply broadly to many types of developments or locations.
• Major Barrier: Code provisions that significantly reduce the feasibility of developing a project that contributes to the City’s housing and climate goals. The degree to which these provisions are barriers may be contingent on other standards or requirements and the barrier may apply to a narrower range of development types of locations.
• Minor Barrier: Code provisions that may have a limited negative impact on the feasibility of developing a project that contributes to the City’s housing and climate goals. The degree to which these provisions are barriers may be contingent on other standards or requirements and the barrier may apply to a narrower range of development types of locations.

Please note that the attached draft does not adequately address the cascading climate barriers identified in the Key Outcomes for each code barrier identified.  Additional work is necessary to refine how the climate barriers identified in the Carbon Neutrality Plan will be addressed in the final draft of this report. 

Co-Benefits: Identify areas, where relevant, reducing or removing a code barrier may have co-benefits or synergistic impacts on both housing and climate goals.

Tensions: Additionally, identify any potential tensions or trade-offs between policy goals that may arise as part of the assessment of code barriers. The consultant team identified two types of conflicts:

• Housing/Climate Tensions: Removing the barrier would advance one of the City’s two primary goals but may constrain the ability to meet the other policy goal.
• Tensions with Other Policy Goals: Removing the barrier may have a negative impact on the City’s ability to meet other policy goals. For example, reducing minimum parking requirements may reduce the cost of housing development, but may also impact neighborhood livability. 

Feasibility of Alternatives: The consultant team, along with staff, will determine and discuss whether there are alternative regulations or standards that are reasonably feasible for the City to implement. Feasibility includes physical, legal, or economic feasibility. Specific alternatives will not be proposed at this stage.

By including all the above information for each code barrier, the City Council will be able to make more informed decisions and prioritize the most critical barriers to achieving housing and climate goals.

Project Outreach
These draft reports and a presentation were presented to the larger city staff steering committee, and the Housing, Sustainability, Transportation, and Planning and Zoning Commissions. At the time of this staff report, only feedback from the Steering Committee meetings was available and is discussed in the attached memo (Attachment A). Additional feedback from the respective commissions and Council will be incorporated into the draft reports before finalizing.

A link to the draft reports and appendices can be found here: https://www.flagstaff.az.gov/4888/Land-Availability-Suitability-StudyCode-