City Policy is Clear on Appropriate Heights for North Hills

Dear Mayor and Members of City Council,

The core issues with this rezoning remain excessive height and insufficient conditions. This request seeks more than double the recommended height for these properties without providing the significant public benefits required by the Comprehensive Plan.

Table LU-2 guidance has historically been treated as the standard for evaluating rezonings. In this case, both LU-2 and MTAP (MIdTown Area Plan) have been disregarded entirely. This is not a minor deviation—the applicant is requesting double the recommended height. Multiple policies are clear that when applicants seek the upper limits of recommended heights (which these are not, because they are above the recommended heights), they must offer public benefits that clearly exceed baseline requirements. The proposed conditions do not meet that threshold:

Stormwater mitigation is already required of any development.

Firehouse funding, while appreciated, does not resolve the long-standing and well-documented capacity issues at Fire Station 9, which already struggles to serve this growing area.

Green space remains privately owned, discretionary, and largely required under existing frontage standards. Without public easements, it is not a true public benefit.

Carbon emission reduction is not a meaningful condition, particularly since no additional entitlement is being granted.

Council is being asked to approve an unprecedented increase in height in exchange for conditions that largely reflect existing requirements. No rezonings above the recommended heights laid out in MTAP have been approved since Council unanimously approved the plan in 2020. 

I respectfully urge Council to deny this rezoning as proposed or require conditions that clearly meet the standard of significant public benefit.

Thank you for your consideration.