Date:  March 14, 2024

To: Mayor and City Council Members 

From: Friends of Flagstaff’s Future (F3) Executive Director, Michele James and the Board of Directors

Subject: March 19 Final Agenda Item 10E – Proposed Zoning Code Amendment to allow residential dwelling uses on land zoned Public Facilities (PF), Consideration and Adoption of Resolution No. 2024-05 and Ordinance No. 2024-03

For almost the last two months, F3 has been carefully considering the impacts and potential consequences of the city’s proposed zoning code amendment that will make residential dwellings a permitted use in the PF zone. We have appreciated the multiple meetings with city staff who kindly took the time to answer our many detailed questions.

Based upon maps and the list of PF zoned parcels the city staff provided us and using the county’s parcel viewer, we have concluded that there are very few city-owned parcels that are suitable for residential dwellings. City staff later confirmed this, suggesting that only two small parcels have this potential. This being the case, the primary beneficiaries of allowing residential uses by right in the PF zone are the private landowners of larger vacant/semi-vacant parcels: FUSD, the Museum of Northern Arizona, and Lowell Observatory. We encourage you to review the map and list so you can see where the possible impacts of this change will be.

We’re concerned that if this proposed amendment is approved without any oversight guardrails, there will no longer be meaningful public engagement in future decisions about how this land is developed for residential dwellings. Normally this would happen through the rezoning process. A lack of oversight could leave our parks vulnerable to development. And, since there is no legally enforceable way to ensure that affordable workforce housing for Flagstaff residents would be built on these parcels, the public would have no ability to comment on what developers are proposing. 

Given our concerns with the original proposal, we were pleased to see that staff is now providing the council with the important option of allowing the public to be involved by requiring a Conditional Use Permit for residential dwelling uses in the PF zone. We strongly encourage the council to include this requirement so at least the public will have the ability to provide feedback to the Planning and Zoning Commission, the body which approves or denies CUP requests. We also urge you to approve the separate resolution (No. 2024-11) that spells out the intent of the council to prioritize affordable workforce housing for Flagstaff residents, and maintain that affordability, on the city-owned PF parcels deemed suitable for this use.

The voters of Flagstaff want to be involved in important city decisions as evidenced by the outcome of last November’s City Charter amendment election. We believe the addition of the CUP requirement, which provides a minimal level of oversight, is absolutely necessary to ensure that the city and the public together can identify and mitigate impacts. Without it, the proposed amendment has no meaningful guardrails, which is not an outcome that F3 can support.