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, one (1) response in favor, zero (0) responses neutral, and two (2) 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.

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-II (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 Dimensions			Minimum Yard Setback			Miscellaneous Lot Requirements
		Code	Zoning District	Area Sq.Ft.	Width Ft.	Depth Ft.	Front Ft.	Side Ft.	Rear Ft.	Minimum Off-Street Parking Spaces	Max Height	Max Impervious Cover
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 21.5.7A- 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. 

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). 

It is the City’s desire to promote safe, orderly, efficient development and ensure compliance with the City’s vision of future growth.

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. 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:
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. 

• 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.

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 PLZC20250062 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.