ADU Amendment T1NC Concerns and DSD/NHSD Response

Meeting with T1NC and DSD 8/23/2022  T1 Concerns and DSD/NHSD Response 


City of San Antonio’s UDC 35-371:

“Accessory and Principal Dwellings


Affordable housing and neighborhood stability are important public objectives in the City of San Antonio. In recent years, accessory dwellings have become an important method to permit families to remain in their homes by securing rental income, while at the same time providing affordable housing for the elderly, single-person households, students, and other needy populations. Accessory dwellings are also known as "carriage houses," "granny flats," or "echo homes" (an acronym for "elder cottage housing opportunities").

The provisions of this section implement Policy 4i (Neighborhoods) of the master plan, which requires the city to permit carefully controlled accessory housing in single-family residential zoning districts.”[1]

Items for Discussion:

  • Two electrical meters- COSA DSD Response requested
    1. Statement of Purpose in the UDC “The provisions of this section implement Policy 4i (Neighborhoods) of the master plan, which requires the city to permit carefully controlled accessory housing in single-family residential zoning districts.” What are the carefully controlled provisions to protect neighborhoods, with existing single family homes with ADUs, from being converted to duplexes and displacing a single-family residential zoning districts?
    2. In 2021, 46% of homes sold in Bexar County were purchased by investors, an increase of 11% from 2020, 35%, of homes sold to investors according to the National Association of Realtors. San Antonio’s 46% was the second highest percentage behind Ft. Worth for the entire state.[2]

What protections exist to ensure the quality of life in neighborhoods from being displaced by investors for their portfolios given the current market conditions?

  1. DSD Permitting of Meters-how will the City ensure a single family ADU has received proper building and electrical inspections before a second meter may be connected by CPS and requirements to maintain the second meter to avoid future displacement of residents?
    1. Many conditions exist today where solar panels are installed without proper City building permits and connected to the CPS grid for operation.
  • Setbacks (see qty. 2 attached sketches for exhibits)- COSA’s Fire Marshal written response requested
    1. Life Safety Concerns exist regarding the spatial relationships and age of structures in the built environment of San Antonio. Not all existing conditions in San Antonio abutting a proposed location for an ADU have a 5’ setback from the property line nor are the structures fire rated.  Structures (homes, garages, and ADUs) built in the 1880s-1940s are built on property lines, do not have fire rated protection on the structures, and may have been converted to ADUs without permitting therefore concerns remain for ADUs (new infill or renovation of existing structure) to be 3’ from these abutting conditions.
    2. New construction of an ADU with a 3’ setback, to be fire rated, the ADU would have blank wall with no fenestration pattern, up to 30’ in height. Recent home and accessory structure fires in neighborhoods where setbacks are less than 5’ from the property lines have resulted in damage to adjacent properties as reported by Chief Hood
    3. T1NC requests a written response from the fire marshal to address that based on the built environment as described in 2) a. of this document that the proposed UDC by City Neighborhood Housing and Services Department (NHSD) amendment will not have an adverse impact on the fire protection and safety in San Antonio’s residential Communities.
  • Drainage-COSA’s StormWater Flood Plain Administrator Response requested
    1. What comments did the City’s Storm water department provide for the proposed UDC amendment in regards to the 3’ setback?
    2. What protections are in place to ensure ADUs do not have an adverse impact to the drainage in the community with only a 3’ setback in areas with mandatory detention when fill is added to a new construction site? San Antonio’s housing stock was constructed prior to lot to lot drainage requirements and the City has identified $3.1 Billion in drainage needs during the 2022 Bond process.


[1] UDC 35-371 Accessory Dwellings

[2] Iszler, Madison. “Nearly half of homes sold in Bexar went to investors in 2021:  at 28%, state rate was the highest in the U.S.” SAEN, May 31, 2022.