Agenda No. 11.
CITY COUNCIL MEMORANDUM
| City Council Meeting: | November 18, 2025 |
| Department: | Planning & Community Development |
| Subject: | Ordinance 25-S-047- Conduct a public hearing and consider a request to rezone approximately 32 acres of land from General Business District-II (GB-2) to Single-Family Residential District (R-2), known as Guadalupe Property Identification Number 64558, City of Schertz, Texas (B.James/L.Wood/D.Marquez). WITHDRAWN BY APPLICANT- Public Hearing will be held / No Action will be taken by City Council |
BACKGROUND
The applicant withdrew Ordinance 25-S-047 on Friday, November 7, 2025. The public hearing was noticed in the San Antonio Express Newspaper on October 29, 2025, so the public hearing at the November 18, 2025 City Council meeting has to occur. However, since the application has been withdrawn, no action will be taken by the City Council.
The following City Council Memorandum is being provided for informational purposes, but again, City Council will not take action / will not vote on Ordinance 25-S-047.
The applicant is proposing to zone approximately 32 acres of land from General Business District-II (GB-2) to Single-Family Residential District (R-2). The subject property is currently undeveloped and is located within the Accident Potential Zone-II (APZ-II).
On September 18, 2025, nineteen (19) public hearing notices were mailed to the surrounding properties within a 200-foot notification boundary of the subject property. At the time of the staff report, three (3) responses in favor, zero (0) responses neutral, and three (3) responses in opposition have been received. A public hearing notice letter was sent to SCUC-ISD and their most recent demographic report and projects are attached. Two notification signs were posted on the property by the applicant on September 16, 2025. A notice was published in the "San Antonio Express" on Wednesday, October 29, 2025. The Planning and Zoning Commission held a public hearing for the item on Wednesday, October 1, 2025. The meeting can be viewed on the City of Schertz YouTube page.
The property is located within the Accident Potential Zone-II (APZ-II), which, per UDC Section 21.5.9- Special Districts, requires that all zone changes within the AICUZ receive an affirmative recommendation from Joint Base San Antonio (JBSA )- Randolph Air Force Base (RAFB) or the zone change will not be approved by the City.
Unified Development Code (UDC) Section 21.5.9.A.2. is as seen below:
A request for development that is not a permitted use by the AICUZ Study, as adopted by the City, or a request for zoning change for property located within the AICUZ requires written notification to Randolph Air Force Base (RAFB) of the proposed development, type occupancy, occupant load, hours of operation, and any special conditions of the project that may include noise, dust, smoke emissions, etc., and any proposed request for a zone change within the AICUZ, with applicable reference the Standard Land Use Code Manual (SLUCM) as adopted in the AICUZ Study. An acknowledgment from RAFB will be requested on the proposed development within 60 days. RAFB may conclude that the proposed development or zoning change should be permitted. Unless RAFB affirmatively recommends to the City that the proposed development or zoning change in the AICUZ be permitted, the development or zoning change will not be approved by the City. Failure on the part of RAFB to respond within 60 days will be deemed to be disapproval.
The subject property has not received an affirmative recommendation from JBSA- Randolph, however the applicant requested that the application proceed without the affirmative recommendation.
Subject Property:
Adjacent Properties:
According to the letter of intent, the subject property is part of a larger development project they are proposing across multiple jurisdictions. The subject 32 acres, zoned General Business District-II (GB-2), are located in the City of Schertz and within the APZ-II. The approximately 27 acres to the east are zoned Single-Family Residential District (R-2) and are in the City of Schertz limits. To the northeast of the subject property are the approximately 43 acres that are already zoned Single-Family Residential District (R-2), and the applicant is currently going through the preliminary plat process. The developed residential property to the north is within Universal City limits. The properties to the west and southwest of the subject property are within Universal City ETJ. The City of Schertz only has jurisdiction over zoning regulations within city limits. Additionally, the Schertz Unified Development Code includes adopted rules and regulations for properties requesting a zone change within the Air Installation Compatible Use Zone (AICUZ), as per UDC Section 21.5.9.A - Air Installation Compatible Use Zone District (AICUZ). Other jurisdictions may not utilize the same rules and regulations within the AICUZ in the same fashion that the City of Schertz does.
The following City Council Memorandum is being provided for informational purposes, but again, City Council will not take action / will not vote on Ordinance 25-S-047.
The applicant is proposing to zone approximately 32 acres of land from General Business District-II (GB-2) to Single-Family Residential District (R-2). The subject property is currently undeveloped and is located within the Accident Potential Zone-II (APZ-II).
On September 18, 2025, nineteen (19) public hearing notices were mailed to the surrounding properties within a 200-foot notification boundary of the subject property. At the time of the staff report, three (3) responses in favor, zero (0) responses neutral, and three (3) responses in opposition have been received. A public hearing notice letter was sent to SCUC-ISD and their most recent demographic report and projects are attached. Two notification signs were posted on the property by the applicant on September 16, 2025. A notice was published in the "San Antonio Express" on Wednesday, October 29, 2025. The Planning and Zoning Commission held a public hearing for the item on Wednesday, October 1, 2025. The meeting can be viewed on the City of Schertz YouTube page.
The property is located within the Accident Potential Zone-II (APZ-II), which, per UDC Section 21.5.9- Special Districts, requires that all zone changes within the AICUZ receive an affirmative recommendation from Joint Base San Antonio (JBSA )- Randolph Air Force Base (RAFB) or the zone change will not be approved by the City.
Unified Development Code (UDC) Section 21.5.9.A.2. is as seen below:
A request for development that is not a permitted use by the AICUZ Study, as adopted by the City, or a request for zoning change for property located within the AICUZ requires written notification to Randolph Air Force Base (RAFB) of the proposed development, type occupancy, occupant load, hours of operation, and any special conditions of the project that may include noise, dust, smoke emissions, etc., and any proposed request for a zone change within the AICUZ, with applicable reference the Standard Land Use Code Manual (SLUCM) as adopted in the AICUZ Study. An acknowledgment from RAFB will be requested on the proposed development within 60 days. RAFB may conclude that the proposed development or zoning change should be permitted. Unless RAFB affirmatively recommends to the City that the proposed development or zoning change in the AICUZ be permitted, the development or zoning change will not be approved by the City. Failure on the part of RAFB to respond within 60 days will be deemed to be disapproval.
The subject property has not received an affirmative recommendation from JBSA- Randolph, however the applicant requested that the application proceed without the affirmative recommendation.
Subject Property:
| Zoning | Land Use | |
|---|---|---|
| Existing | General Business District (GB-2) | Agriculture/ Undeveloped |
| Proposed | Single-Family Residential District (R-2) | Single-Family |
Adjacent Properties:
| Zoning | Land Use | |
|---|---|---|
| North | Out of City Limits- Universal City ETJ | Agriculture/ Homes |
| South | General Business District-II (GB-2) & General Business District (GB) |
Undeveloped/ Soccer Fields- City of Schertz Owned Property |
| East | Single-Family Residential District (R-2) | Undeveloped |
| West | Out of City Limits- Universal City ETJ | Agriculture/ Undeveloped |
| Dimensional Requirements | ||||||||||||
|---|---|---|---|---|---|---|---|---|---|---|---|---|
| Minimum Lot Size | Minimum Yard Setback | Miscellaneous Lot Requirements | ||||||||||
| Code | Zoning District | Area sq.ft | Width | Depth Ft. | Front Ft. | Side Ft. | Rear Ft. | Minimum Off-Street Parking Requirements | Max Height | Max. Impervious Coverage | ||
| Table 21.5.7.B- Dimensional Requirements Non-Residential Zoning Districts | Existing | GB-II | General Business District- II | 10,000 | 100 | 100 | 25 | 0 adj. to non-res./ 25 adj. to res | 0 adj. to non-res./ 25 adj. to res | Article 10 Parking Standards | 120 | 80% |
| Table 21.5.7.A- Dimensional Requirements Residential Zoning Districts | Proposed | R-2 | Single-Family Residential | 8,400 | 70 | 120 | 25 | 10 | 20 | 2 | 35 | 50% |
According to the letter of intent, the subject property is part of a larger development project they are proposing across multiple jurisdictions. The subject 32 acres, zoned General Business District-II (GB-2), are located in the City of Schertz and within the APZ-II. The approximately 27 acres to the east are zoned Single-Family Residential District (R-2) and are in the City of Schertz limits. To the northeast of the subject property are the approximately 43 acres that are already zoned Single-Family Residential District (R-2), and the applicant is currently going through the preliminary plat process. The developed residential property to the north is within Universal City limits. The properties to the west and southwest of the subject property are within Universal City ETJ. The City of Schertz only has jurisdiction over zoning regulations within city limits. Additionally, the Schertz Unified Development Code includes adopted rules and regulations for properties requesting a zone change within the Air Installation Compatible Use Zone (AICUZ), as per UDC Section 21.5.9.A - Air Installation Compatible Use Zone District (AICUZ). Other jurisdictions may not utilize the same rules and regulations within the AICUZ in the same fashion that the City of Schertz does.
GOAL
The applicant is proposing to rezone approximately 32 acres in the APZ-II from General Business District-II (GB-II) to Single-Family Residential District (R-2).
COMMUNITY BENEFIT
It is the City’s desire to promote safe, orderly, efficient development and ensure compliance with the City’s vision of future growth.
SUMMARY OF RECOMMENDED ACTION
When considering zone changes, Staff uses the criteria listed in UDC Section 21.5.4.D. The criteria are listed below:
1. Whether the proposed zone change implements the policies of the adopted Comprehensive Land Plan, or any other applicable adopted plans.
The proposed zone change does not implement the policies of the adopted Comprehensive Plan and other adopted plans. The Comprehensive Land Use Plan - Future Land Use map designates the subject property as Complete Neighborhood. The Complete Neighborhood Land Use Designation is intended for a mixture of housing options, supporting land uses, and neighborhood commercial. When considering the appropriateness of housing density or commercial activity, factors such as roadway classification, conflicts among land uses, and buildings should be considered.
The subject property is located in the APZ-II and is proposing to rezone to a single-family residential district that would allow a density of approximately 5.2 dwelling units per acre, a total of 166 new homes on the 32 acres. All 32 acres of the subject property would be able to be developed as the Single-Family Residential District (R-2) and the City would not be able to restrict the density or building areas with the straight zoning proposed. When considering the proposed residential density and the existing APZ-II area that encumbers the subject property, the proposed residential zoning is not appropriate at the specified location and creates conflicts among land uses.
2. Whether the proposed zone change promotes the health, safety, and general welfare of the City.
The proposed Single-Family Residential District (R-2) does not promote the health, safety, and general welfare of the City, as it does not meet the Unified Development Code requirements as stipulated in UDC Section 21.5.9- Special Districts. All zone changes located within the Air Installation Compatible Use Zone District (AICUZ) are required to comply with Section 21.5.9 and receive an affirmative recommendation from JBSA- Randolph.
UDC Section 21.5.9.A.2 contains the sentence below.
Unless RAFB affirmatively recommends to the City that the proposed development or zoning change in the AICUZ be permitted, the development or zoning change will not be approved by the City.
The applicant requested a response from JBSA- Randolph two times, and with both requests, did not receive an affirmative recommendation, as required by the UDC. Per the UDC, "the development or zoning change will not be approved by the City."
In the letter from JBSA, dated April 9, 2025 they communicated the following to the applicant:
In the letter from JBSA dated May 22, 2025, they communicated the following to the applicant:
Here is an example of an affirmative recommendation letter received by a different zone change application in the AICUZ, PLZC20250094 36 and 40 Maske Road.
The two letters the proposed zone change received do not include the affirmative recommendation language as required per the UDC and received by other applications in the AICUZ.
Since the zone change does not meet the Unified Development Code requirements, as it did not receive an affirmative recommendation from JBSA, it does not promote the health, safety, and general welfare of the City.
The policies of the Comprehensive Plan stipulate collaboration with stakeholders. One of the recommended strategies is to prioritize collaboration among the stakeholders involved in the area's development with regular engagement. The Unified Development Code has procedures set in place to ensure collaboration with JBSA- Randolph by requiring an affirmative recommendation. By not obtaining an affirmative recommendation from JBSA- Randolph as per the UDC, the proposed zone change does not promote the health, safety, and general welfare of the City.
As part of the zone change application, the applicant provided a TIA Determination form. The Schertz Engineering Department has reviewed the submitted TIA Determination Form and summarized that the requested change in zoning from General Business District-II (GB-2) to Single-Family Residential District (R-2) would not have an adverse impact on the transportation system in comparison to the existing GB-2. A full Traffic Impact Analysis will be required during the development process, and the developer will be required to construct any mitigation improvements required to counter any adverse impacts to the transportation system created by the additional development traffic.
3. Whether the uses permitted by the zone change will be consistent and appropriate with existing uses in the immediate area.
The proposed zoning district of Single-Family Residential District (R-2) allows for single-family residences together with schools, churches, and parks.
The property is within the Airport Installation Compatible Use Zone District (AICUZ), more specifically, the APZ-II of JBSA-Randolph. Although single-family residential is not incompatible in the AICUZ, the density of the proposed Single-Family Residential District (R-2) is not compatible and was not able to receive an affirmative recommendation from JBSA for the 32-acres of the subject property.
4. Whether other factors are deemed relevant and important in the consideration of the amendment.
The proposed zone change does not meet the Unified Development Code requirements. The zone change application did not receive an affirmative recommendation from JBSA- Randolph as required per UDC Section 21.5.9.A.2. Other zone change applications in the AICUZ have worked with JBSA-Randolph to obtain an affirmative recommendation, even when it may not have been obtained with the first request.
The proposed zone change was also sent to the City of Schertz Fire, EMS, and Police Departments for their review.
At the Wednesday, October 1, 2025, Planning and Zoning Commission meeting, there was a lengthy discussion on the calculation of the density the applicant was proposing and the lack of an affirmative recommendation from JBSA. There was also discussion on the intent of the APZ-II and the compatibility of single-family residences within the APZ-II.
1. Whether the proposed zone change implements the policies of the adopted Comprehensive Land Plan, or any other applicable adopted plans.
The proposed zone change does not implement the policies of the adopted Comprehensive Plan and other adopted plans. The Comprehensive Land Use Plan - Future Land Use map designates the subject property as Complete Neighborhood. The Complete Neighborhood Land Use Designation is intended for a mixture of housing options, supporting land uses, and neighborhood commercial. When considering the appropriateness of housing density or commercial activity, factors such as roadway classification, conflicts among land uses, and buildings should be considered.
The subject property is located in the APZ-II and is proposing to rezone to a single-family residential district that would allow a density of approximately 5.2 dwelling units per acre, a total of 166 new homes on the 32 acres. All 32 acres of the subject property would be able to be developed as the Single-Family Residential District (R-2) and the City would not be able to restrict the density or building areas with the straight zoning proposed. When considering the proposed residential density and the existing APZ-II area that encumbers the subject property, the proposed residential zoning is not appropriate at the specified location and creates conflicts among land uses.
2. Whether the proposed zone change promotes the health, safety, and general welfare of the City.
The proposed Single-Family Residential District (R-2) does not promote the health, safety, and general welfare of the City, as it does not meet the Unified Development Code requirements as stipulated in UDC Section 21.5.9- Special Districts. All zone changes located within the Air Installation Compatible Use Zone District (AICUZ) are required to comply with Section 21.5.9 and receive an affirmative recommendation from JBSA- Randolph.
UDC Section 21.5.9.A.2 contains the sentence below.
Unless RAFB affirmatively recommends to the City that the proposed development or zoning change in the AICUZ be permitted, the development or zoning change will not be approved by the City.
The applicant requested a response from JBSA- Randolph two times, and with both requests, did not receive an affirmative recommendation, as required by the UDC. Per the UDC, "the development or zoning change will not be approved by the City."
In the letter from JBSA, dated April 9, 2025 they communicated the following to the applicant:
"PLZC20250062 Proposed Rezone to R-2 in APZ-II has been reviewed by JBSA-RND organization. JBSA recommends addressing the following comments before moving forward in the planning and development process.
a. Proposed City of Schertz RZ Zoning Category would permit minimum 8,400 sq ft (70'x120') lots within the APZ II. At 25-acres, the proposed zoning category of R2 could permit up to 129 lots. The proposed exhibit displays 77 units within the subject 25-acre portion of the proposed MDP, bringing the proposed density to 3.08 du/acre/ This exceeds the recommended compatible maximum density of 2 du/acre within APZ II per the 2017 RND AFB AICUZ Land Use Compatibility Tables, SLUCM no. 11, Residential, Single units: detached. Request clarification from the applicant on total proposed units within 25-acre portion of APZ II."
a. Proposed City of Schertz RZ Zoning Category would permit minimum 8,400 sq ft (70'x120') lots within the APZ II. At 25-acres, the proposed zoning category of R2 could permit up to 129 lots. The proposed exhibit displays 77 units within the subject 25-acre portion of the proposed MDP, bringing the proposed density to 3.08 du/acre/ This exceeds the recommended compatible maximum density of 2 du/acre within APZ II per the 2017 RND AFB AICUZ Land Use Compatibility Tables, SLUCM no. 11, Residential, Single units: detached. Request clarification from the applicant on total proposed units within 25-acre portion of APZ II."
In the letter from JBSA dated May 22, 2025, they communicated the following to the applicant:
" PLZC20250062- Proposed Rezone to R-2 in APZ-II Updated Application has been reviewed by JBSA-RND organizations. JBSA recommends addressing the following comments for consideration in the planning and development process.
a. Approximately 32-acres of the subject tract are located w/in JBSA RND runway 15L/33R Accident Potential Zone II (APZ-II). Per the 2017 RND AFB Air Installation Compatible Use Zone (AICUZ) study, maximum recommended density for single-family land uses w/in APZ-II is not to exceed 2 dwelling units/acre. JBSA recommends application of the above 2 dwelling units/acre single-family land use maximum density as applied to the subject 32-acre parcel, through the establishment of the appropriate, flexible, City of Schertz Zoning District as identified within Article 5, Sec. 21.5.9- Special Districts, of The City of Schertz Unified Development Code."
a. Approximately 32-acres of the subject tract are located w/in JBSA RND runway 15L/33R Accident Potential Zone II (APZ-II). Per the 2017 RND AFB Air Installation Compatible Use Zone (AICUZ) study, maximum recommended density for single-family land uses w/in APZ-II is not to exceed 2 dwelling units/acre. JBSA recommends application of the above 2 dwelling units/acre single-family land use maximum density as applied to the subject 32-acre parcel, through the establishment of the appropriate, flexible, City of Schertz Zoning District as identified within Article 5, Sec. 21.5.9- Special Districts, of The City of Schertz Unified Development Code."
Here is an example of an affirmative recommendation letter received by a different zone change application in the AICUZ, PLZC20250094 36 and 40 Maske Road.
"Zone change in APZ-II PLZC20250094- Maske Road Business Park (36 &40 Maske Road)1. Zone Change in APZ II PLZC20250094- Maske Road Business Park (36 & 40 Maske Road) has been reviewed by JBSA- RND organizations. JBSA affirmatively recommends the proposed zoning change is permitted, however there are additional comments for consideration in planning and development."
The two letters the proposed zone change received do not include the affirmative recommendation language as required per the UDC and received by other applications in the AICUZ.
Since the zone change does not meet the Unified Development Code requirements, as it did not receive an affirmative recommendation from JBSA, it does not promote the health, safety, and general welfare of the City.
The policies of the Comprehensive Plan stipulate collaboration with stakeholders. One of the recommended strategies is to prioritize collaboration among the stakeholders involved in the area's development with regular engagement. The Unified Development Code has procedures set in place to ensure collaboration with JBSA- Randolph by requiring an affirmative recommendation. By not obtaining an affirmative recommendation from JBSA- Randolph as per the UDC, the proposed zone change does not promote the health, safety, and general welfare of the City.
As part of the zone change application, the applicant provided a TIA Determination form. The Schertz Engineering Department has reviewed the submitted TIA Determination Form and summarized that the requested change in zoning from General Business District-II (GB-2) to Single-Family Residential District (R-2) would not have an adverse impact on the transportation system in comparison to the existing GB-2. A full Traffic Impact Analysis will be required during the development process, and the developer will be required to construct any mitigation improvements required to counter any adverse impacts to the transportation system created by the additional development traffic.
3. Whether the uses permitted by the zone change will be consistent and appropriate with existing uses in the immediate area.
The proposed zoning district of Single-Family Residential District (R-2) allows for single-family residences together with schools, churches, and parks.
The property is within the Airport Installation Compatible Use Zone District (AICUZ), more specifically, the APZ-II of JBSA-Randolph. Although single-family residential is not incompatible in the AICUZ, the density of the proposed Single-Family Residential District (R-2) is not compatible and was not able to receive an affirmative recommendation from JBSA for the 32-acres of the subject property.
4. Whether other factors are deemed relevant and important in the consideration of the amendment.
The proposed zone change does not meet the Unified Development Code requirements. The zone change application did not receive an affirmative recommendation from JBSA- Randolph as required per UDC Section 21.5.9.A.2. Other zone change applications in the AICUZ have worked with JBSA-Randolph to obtain an affirmative recommendation, even when it may not have been obtained with the first request.
The proposed zone change was also sent to the City of Schertz Fire, EMS, and Police Departments for their review.
- Police and EMS do not have specific concerns over the proposed zone change.
- The Fire Department has concerns with potential residential development within the JBSA flight path due to the additional potential of accidents in the APZ.
At the Wednesday, October 1, 2025, Planning and Zoning Commission meeting, there was a lengthy discussion on the calculation of the density the applicant was proposing and the lack of an affirmative recommendation from JBSA. There was also discussion on the intent of the APZ-II and the compatibility of single-family residences within the APZ-II.
RECOMMENDATION
Staff Recommendation:
UDC Section 21.5.9.A.2. stipulates that unless Randolph Air Force Base (RAFB) affirmatively recommends to the City that the proposed development or zoning change in the Air Installation Compatible Use Zones (AICUZ) be permitted, the development or zoning change will not be approved by the City.
Staff recommends denial of Ordinance 25-S-047 for not meeting the Unified Development Code requirements, as the applicant has failed to obtain an affirmative recommendation from JBSA-Randolph as per UDC Section 21.5.9.A.2.
Planning and Zoning Commission Recommendation:
The Planning and Zoning Commission held a public hearing for the item on October 1, 2025. The Planning and Zoning Commission made a recommendation of denial to City Council with a unanimous vote.
The applicant withdrew Ordinance 25-S-047 on Friday, November 7, 2025. The public hearing was noticed in the San Antonio Express Newspaper on October 29, 2025, so the public hearing at the November 18, 2025 City Council meeting has to occur. However, since the application has been withdrawn, no action will be taken by the City Council.
UDC Section 21.5.9.A.2. stipulates that unless Randolph Air Force Base (RAFB) affirmatively recommends to the City that the proposed development or zoning change in the Air Installation Compatible Use Zones (AICUZ) be permitted, the development or zoning change will not be approved by the City.
Staff recommends denial of Ordinance 25-S-047 for not meeting the Unified Development Code requirements, as the applicant has failed to obtain an affirmative recommendation from JBSA-Randolph as per UDC Section 21.5.9.A.2.
Planning and Zoning Commission Recommendation:
The Planning and Zoning Commission held a public hearing for the item on October 1, 2025. The Planning and Zoning Commission made a recommendation of denial to City Council with a unanimous vote.
The applicant withdrew Ordinance 25-S-047 on Friday, November 7, 2025. The public hearing was noticed in the San Antonio Express Newspaper on October 29, 2025, so the public hearing at the November 18, 2025 City Council meeting has to occur. However, since the application has been withdrawn, no action will be taken by the City Council.
Attachments
- Ordinance 25-S-047 With Attachments
- Aerial Exhibit
- Notification Map
- Public Hearing Responses
- Zoning Exhibit
- JBSA Response April 2025
- JBSA Reponse May 2025
- Example of JBSA Response with an Affirmative Recommendation
- Letter of Intent
- SCUC ISD Demographic Report
- SCUC ISD 10- Year Forecasting
- City Council Presentation Slides