HomeMy WebLinkAboutIR 8032 INFORMAL REPORT TO CITY COUNCIL MEMBERS No. 8o32
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I. To the Mayor and Members of the City Council October 22, 1996
Page 1 of 8
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rkax subject: City Regulations for the Platting of Subdivisions
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EXECUTIVE SUMMARY
Tarrant County recently rescinded a policy to require platted lots prior to the
issuance of an on-site waste disposal (septic) permit. In their deliberation of the
order to rescind this policy, the Commissioners Court cited disagreement with the
City's subdivision regulations requiring a minimum lot size of 2.5 acres when the
lot is to be served with an on-site waste disposal system. The immediate effect of
the County's new policy is that development can occur in the unincorporated areas
of Tarrant County without compliance with State subdivision requirements, which
mandate that all property divided into tracts less than 5 acres in size be platted.
Tarrant County will require only that property conform to regulations adopted by
the State for installation of on-site waste disposal systems and private wells.
Generally, these regulations require 0.5 acre for an on-site waste disposal system
and 1 acre for both a private well and on-site waste disposal system and do not
address the need for a platted lot.
The City's subdivision regulations are adopted by the City Council after receiving
a recommendation from the Plan Commission. As determined by State law, the
City's Plan Commission is the municipal authority responsible for approving all
plats within the City's platting jurisdiction (the corporate limits and area within a 5
mile radius of the corporate limits referred to as the extraterritorial jurisdiction or
ETJ). The Plan Commissions' discretion is limited since State law requires that
plats that meet the subdivision requirements of the City must be approved. All
plats in the unincorporated areas of Tarrant County must also be approved by the
Tarrant County Commissioners Court.
In formulating a response to the County's action, several factors should be
considered by the City:
• Mechanisms for ensuring compliance with State regulations for platting
property in the unincorporated areas of the County;
• Provisions of adequate infrastructure (including wastewater disposal) for
developing areas in the unincorporated areas of the County realizing that
these areas may be annexed into corporate limits in the future;
• Legal authority for the City to impose minimum lot standards o ,,ECUR
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ISSUED BY THE CITY MANAGER FORT WORTH, TEXAS
INFORMAL REPORT TO CITY COUNCIL MEMBERS No. 8032
cT�a�o October 22, 1996
oar To the Mayor and Members of the City Council
fij� Page 2 of 8
'R= s Subject: City Regulations for the Platting of Subdivisions
,an
subdivision regulations.
The following report provides more detail concerning these issues and outlines
staff recommendation for action.
BACKGROUND
The Texas Local Government Code requires that all property divided into parcels
less than five acres in size must be platted. Property within a five mile radius of
Fort Worth's city limits (referred to as the City's extraterritorial jurisdiction, or
ETJ) must be platted according to the subdivision regulations of the City. These
plats require approval by the City Plan Commission and the Tarrant County
Commissioners Court. Since neither the City nor the County have the authority to
issue building permits in the ETJ, there are limited means to enforce the State-
mandated platting process. Since April, 1993 the County has maintained a policy
that requires a platted lot prior to issuing a septic permit, thus providing a
mechanism to ensure that property is platted in conformance with State
requirements. This policy was rescinded by action of the Commissioners Court on
September 24, 1996 with the result that the County no longer requires proof of a
platted lot prior to issuing a septic permit. This action effectively removes much of
the incentive for owners to plat their property in conformance with State
requirements. The issue driving the County's rescission of the policy requiring a
platted lot in order to issue a septic permit was the City's platting requirements for
rural type lots, especially the requirement for a rural lot to be a minimum size of
2.5 acres.
The Plan Commission Rules and Regulations (adopted by the Mayor and Council)
allow two types of platted lots: urban and rural. The urban lot is the traditional
type of platted lot marked by moderate to high density and infrastructure
improvements that include curbed streets, a storm water drainage system,
connections to a water main, and a collective sewer system. The second type of
platted lot,:the rural lot, is characterized by low density and minimum
ISSUED BY THE CITY MANAGER FORT WORTH, TEXAS
API
INFORMAL REPORT TO CITY COUNCIL MEMBERS No. 8032
&,_0TENto October 22, 1996
o+ +rw To the Mayor and Members of the City Council Page 3 of 8
* rr Subject: City Regulations for the Platting of Subdivisions
1873
infrastructure improvements. Streets are not necessarily constructed with curbs or
storm water systems, water service may be provided by private wells, and there
may be no provision for connection to a sewer system, requiring the installation of
on-site disposal for waste water (septic systems). This dual system of development
standards was adopted in July 1991, after the City experienced a significant
increase in the type and character of development occurring throughout the City's
platting jurisdiction, both in and out of the City limits. Prior to 1991, the
subdivision regulations made no distinction of the type of lot platted.
During the late 1980's and early 1990's, plats consisting of 200 to 300 lots for
single family residential developments were submitted for approval by the Plan
Commission. Many of these developments were proposed for urban-type
densities, but with rural type improvements, including on-site waste disposal
systems. Some of these proposed subdivisions generated opposition from adjacent
land owners who voiced concerns at public hearings concerning the viability of
the use of on-site waste disposal given the proposed lot density. These adjacent
land owners testified that their own experience with on-site systems indicated that
poor performance would also occur in the proposed developments. The plats were
denied based on insufficient evidence for the appropriate provision of wastewater
disposal. The opposition to these proposed plats came from County residents
living in the unincorporated areas.
In response to the concerns raised regarding moderate to high density subdivisions
served by on-site waste disposal, the Plan Commission held a series of public
hearings specifically to consider the adoption of standards for rural type
subdivisions. Although wastewater disposal was a significant concern, other
important issues centered on street construction design criteria and other
infrastructure issues. After these public hearings, the current rural lot policy was
adopted.
The City's large lot regulations may be summarized as follows:
• This policy applies both inside and outside the City limits; Mini 1�f JWL
size is 2.5 acres; Use of alternate water and wastewater disposal s s s
ISSUED BY THE CITY MANAGER FORT WORTH,TEXAS
J
INFORMAL REPORT TO CITY COUNCIL MEMBERS No. 8032
To the Mayor and Members of the City Council October 1996
Page 4 of 8
a�� x
>• • subject: City Regulations for the Platting of Subdivisions
(private wells and on-site or septic systems) may be approved by the Plan
Commission. Alternate systems may also include private, collective water
and wastewater systems;
• Streets - Streets are required to meet County, not City, standards;
• Storm water - Drainage may be provided by open channel;
• Parkland - No parkland dedication requirements are in effect for plats in the
ETJ.
In October 1992, the Plan Commission denied a variance to allow lots less than
2.5 acres in size for a proposed subdivision called Lake Ridge Addition.
Opposition to the variance was expressed by County residents representing the
Benbrook Lakeshore Homeowners' Association. The City is currently involved in
litigation with the owner of this subdivision as to whether or not the City had the
authority to require the minimum lot size of 2.5 acres. On April 27, 1993 the
Tarrant County Commissioner's Court adopted Order No. 68829 requiring
compliance with the subdivision regulations of the City with platting jurisdiction
in the unincorporated area of the ETJ prior to issuing an on-site waste disposal
permit.
It is the minimum lot size requirement that has resulted in the recent rescission of
the County's policy to require platted lots prior to issuance of septic permits, with
the indication that County officials believe the lot size to be excessive. The
County now enforces only the State regulations adopted by the Texas Natural
Resource Conservation Commission on March 1, 1992. These regulations require
the following for issuance of a septic permit:
1. A minimum lot size of.5 acres for property served by a public water
supply;
2. A minimum lot size of 1 acre for property that is served by an
individual private water well;
3. An exception to the above minimums based on an approved site-
specific design submitted by a registered professional engineer or a
registered professional sanitarian.
ISSUED BY THE CITY MANAGER FORT WORTH,TEXAS
INFORMAL REPORT TO CITY COUNCIL MEMBERS No. 8032
G'" TEpFo October 22, 1996
uU:,. To the Mayor and Members of the City Council
Page S of 8
subject: City Regulations for the Platting of Subdivisions
,971
The exception noted does allow areas less than .S acre in size to be permitted for
on-site waste disposal.
DISCUSSION
The following discussion centers on the issues associated with the possible
revision of the City's minimum lot size requirements for rural subdivisions.
Public Health Significance
Failure of a septic system in a highly populated area is a fundamental cause of
public health hazards. Sewage contains bacteria and viruses that may cause
disease. Properly treated sewage prevents these harmful organisms from:
1) entering the air we breath; 2) coming into contact with humans, pets, animals,
and insects; and 3) polluting the groundwater and potentially contaminating
drinking water supplies. When many people live in the vicinity, concern increases
over the spread of disease. Sewage systems using soil absorption for liquid waste
disposal are more likely to malfunction in high density situations because the soil
available to absorb the liquid waste is limited.
Because of these health concerns, the State has established regulations to control
the installation of on-site waste disposal systems and private water wells. These
regulations, however, may be supplemented by local ordinance. Cities or Counties
may not require less than the minimum requirements, but may establish standards
which will produce a higher quality of operation based on sound engineering
principles. At this time, neither Tarrant County nor Fort Worth have enacted
regulations to supplement the State requirements.
Development-Related Issues
The County's response to the City's rural lot size requirements focuses only on the
provision of septic systems, since the County has permitting responibllit for
these systems. However, the City's minimum lot size requirements r t of� w
1
ISSUED BY THE CITY MANAGER FORT WORTH,TEXAS
INFORMAL REPORT TO CITY COUNCIL MEMBERS No. 8032
TEa�o October 22, 1996
To the Mayor and Members of the City Council �,
Page 6 of 8
.'
X City Regulations for the platting of Subdivisions
1873
network of regulations designed to accommodate rural type-development. Since
platting requirements are the City's prerogative in our ETJ by State law, these
requirements set the standards for the development of land that may someday be
annexed into the City limits.
The basic premise of mandating large lot sizes for subdivisions that are served by
"rural-style" infrastructure is that these types of streets, drainage, and water and
wastewater systems do not function effectively with high levels of use. The
regulations allow a lower level of infrastructure services in accordance with lower
levels of demand and use of these systems. This provides an economically feasible
means to develop when low density is desired. The regulations also help to ensure
that if these areas are annexed in the fixture, the City does not "inherit" areas where
infrastructure has been insufficient and requires tax dollars to upgrade existing
systems. ;,,
Although the County Commissioners' current concerns center on the minimum lot
size, future concerns could focus on other aspects of the City's subdivision
regulations. From a development viewpoint, the critical factor is that development
in the City's ETJ occur within the platting process as required by State law. This is
the only way to provide for orderly provision of necessary infrastructure in those
areas. Any policy enacted by the City or County that may provide a disincentive to
platting and allow development based on a metes and bounds division of property
is not in the interest of either jurisdiction.
Legal Issues
State law provides that a municipality may not impose zoning regulations in the
ETJ, such as regulations governing use, building size and height, or floor to area
ratios. In addition, a municipality may not regulate "the number of residential units
that can be built per acre of land." A question posed by the Commissioners Court
is whether the City has the authority to establish a minimum lot size regulation for
rural subdivisions. "ON
ISSUED BY THE CITY MANAGER FORT WORTH,TEXAS
INFORMAL REPORT TO CITY COUNCIL MEMBERS No. 8032
eEtq.rER October 22, 1996
To the Mayor and Members of the City Council page 7 of8
Subject: City Regulations for the Platting of Subdivisions
1871
It is staff's position that establishment of regulations concerning minimum lot
sizes is an inherent part,of establishing rules governing plats and subdivisions, so
that the 2.5 acre regulation is valid so long as it promotes the health, safety or
general welfare of the City and safe, orderly and healthful development. If the City
is not allowed to establish minimum lot sizes for residential developments because
they would constitute a regulation of the number of residential units that can be
built on an acre of land, then the City would not be able to impose meaningful
subdivision rules for residential developments in the ETJ.
Policy Alternatives
Several policy alternatives are available to the City. The Council may wish to refer
discussion of these alternatives to the appropriate Council committee.
1. Consider adoption of a reduced lot size requirement for rural subdivisions.
This alternative is offered in response to the concerns expressed by the
County. It should be realized, however, that consideration of the minimum
lot size requirement does not address the basic issue of enforcement of State
platting requirements in the ETJ.
2. Maintain the existing regulations with the assumption that the County will
maintain its newly adopted policy. This will effectively mean that there will
be very little incentive for land in the City's ETJ to be platted prior to
development. If this policy is considered, alternative mechanisms for
enforcement of the State's platting regulations should be sought.
RECOMMENDATION
Based on the desire of the Council or Council committee to pursue alternative one,
the following recommendations are offered:
1. Direct the Plan Commission to conduct public hearings and consider t „„...... �
amendment of the City's regulations regarding rural subdivisi r9flonotlic
WORTIV
ISSUED BY THE CITY MANAGER FO ' ''FORTH,TEXAS- ___
INFORMAL REPORT TO CITY COUNCIL MEMBERS No. 8032
'T October 22, 1996
To the Mayor and Members of the City Council Page 8 of
subject: City Regulations for the Platting of Subdivisions
re»
2. Direct the Law Department to research mechanisms for enforcement of the
State's atting regulations in the ETJ.
Bob Terrell
City Manager
l
ISSUED BY THE CITY MANAGER FORT WORTH,TEXAS