Blog An Explanation of Tucson for Everyone’s Proposed Code Edits

Introduction

Tucson for Everyone is very enthusiastic about the proposed CODE Tucson ‘26 effort, which we view as a much-needed step to bring our outdated and opaque code into the present. We are excited to see the Unified Development Code (UDC) made simpler, clearer, more consistent, more navigable, and more reflective of our community’s priorities. The draft redlines proposed on May 28 identify and resolve many longstanding issues with the UDC. However, they also leave many significant issues unaddressed and—in some cases—introduce new inconsistencies. This document summarizes our feedback for Code Tucson ‘26 and summarizes the changes in the attached code edits.

Importance

The current UDC contains many errors from incorrect references to unclear wording to grammar issues.. This culminates in a code that is difficult to comprehend and use as a tool for regulating and guiding development. Our proposed changes aim to resolve issues and errors in the UDC that remain untouched.

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In addition to greater accuracy and clarity we are also proposing several changes to policy. These are designed to align with transportation and environmental goals and allow for greater flexibility for residential development. A complete explanation of all proposed policy changes can be found further in this article. Our proposed UDC improvements also deliver progress on 11 of our residents’ 14 priorities identified in Plan Tucson.

Clarity

While reviewing the City’s proposed changes, we came across additional sections with errors, incorrect references, inconsistency, or other ambiguity. Our proposed changes aim to resvole a greater number of these issues, including:

• The Administrative Manual is inconsistent with the UDC and contains outdated provisions. Our changes suggest revisions to fix these.
  
• §3.12.3.D: The proposed redlines still leave this section difficult to understand. Our proposed edits make it clear that there is a hard height limit of 55 ft. and simplify the wording into one statement.
  
• §6.6.2.L: The cistern standards are unclear and leave ambiguity, our proposed version resolves this adopting language that leaves no height or size possibility undefined.
  
• Miscellaneous spelling or wording errors.
  

Definitions

• §11.3.7.A: Terms used across the UDC are inconsistent and overlapping. The fundamental problem is that existing definitions are based on different concepts: the number of homes on a site, the physical form of a dwelling (attached, detached), its construction method (manufactured, mobile, on-site), and a building’s relationships to others (primary, accessory). Our changes propose definitions along the following standards, and update all relevant sections and references to match.
• Number of homes on a site
  • Single-Family Development: 1 unit
  • Middle Housing Development: 2 - 4 units
  • Multifamily Development: 5 or more units
• Physical Form
  • “Attached” and “Detached” are used to classify building-form types
• Construction Method
  • “Manufactured Housing” is used to classify a construction method
• Site Relationship
  • “Accessory” is used to classify a relationship of one dwelling to another

There are several reasons we believe that clarification of these definitions is critically important:

• In order for middle housing to be realized as an affordable alternative to traditional single-family construction, those projects must clearly qualify for the streamlined provisions intended for them in several sections of the UDC.
• Ambiguous definitions in our local code compound the already ambiguous underwriting standards used by lenders. This means middle housing projects face enormous barriers to qualifying for all four major types of loans—Conventional (set by Fannie Mae & Freddie Mac), USDA, FHA, and VA. Of these, two are especially important:
  • USDA loans, which contain special provisions to finance development in underserved rural areas.
  • FHA loans, which contain extensive provisions to finance rehabilitation and expansion of dilapidated structures.

Removing barriers for members of our community to access these loan options would help drive investment and prosperity in Tucson.

• Several provisions in the ROAD to Housing Act expand financing options for specific types of housing: §301 for manufactured homes, §302 for modular housing, §303 for manufactured housing, and §804 for workforce housing. These changes me be required soon, but we will see the greatest effects if we are proactive.

Lot Sizes:

CODE Tucson ‘26 proposes using density ratios to regulate Middle Housing development, such as 4 dwelling units per 6,000 sq. ft. We believe that aligning our lot sizes to these densities is a more direct approach, and has the added benefit of better facilitating infill development by allowing it to be done gradually. Our changes are:

• In R-2, R-3, and MH-2 zones, we propose a minimum lot size of 1,000 sq. ft. to match the existing 4/4,000 sq ft.
• In R-1 and MH-1 zones, we propose a minimum lot size of 1,500 sq. ft. to match the existing 4/6,000 sq. ft.
• For O-1 and O-2 zones, we propose a residential density limit of 1/1,500 sq. ft. for Middle Housing and Multifamily Development.
• For zone O-3, we have proposed 1/1,000 sq. ft. The current 8/acre density limit for O-1 and O-2 will be removed as it is overridden by Middle Housing.

Note—we are not proposing shrinking lot sizes for O-1, O-2, and O-3; however, we are including Middle Housing in “Res” for added consistency. Densities and lot sizes for Commercial zones were not altered as their minimum lot sizes are already zero.

Parking:

CODE Tucson ‘26 proposes clarifications and small reforms for parking; however, a great amount of complexity still exists within the parking standards. Tucson for Everyone proposes the following edits to simplify parking minimum requirements and allow slightly more flexibility.

• Residential Developments of one to five dwelling units are required to have one space per dwelling unit.
• Allows all multifamily development to use the simpler standards currently defined for large developments, and sets a lower requirement for small units:
  • Studio or One Bedroom - 1.00 space per dwelling unit
  • Two or More Bedrooms - 1.25 spaces per dwelling unit
• Moves the parking waiver for Middle Housing from 4.9.7.B-12 to Section 7.4.5.C to consolidate all parking reductions and exemptions in one place. Expands the waiver criteria to be applicable to all residential developments of one to five dwelling units, and to Residential Care Services with ten or fewer residents. Changes the language to immediately waive parking for developments meeting the current ¼ mile to transit or bikeway criteria.
• Note—none of the changes bypass the single-family R-1 requirement (currently UDC §4.9.7.B.7).

Future Possibilities

Looking beyond the current scope of changes, Tucson for Everyone is deeply interested in how future changes to the UDC can further align with new emerging consensus on planning best practices. For example, even with our proposed changes, Tucson’s development code will still have burdensome parking minimum requirements, especially for commercial establishments such as bars. As highlighted below, other cities in Arizona and elsewhere have already adopted more flexible standards or have removed parking minimums for some developments entirely. Future code change proposals should include further reductions in parking minimum requirements.

Another area of change that should be considered is raising the maximum height limit for R-2 and R-3 zones. Tucson currently has a 25 ft height limit across most residential zones in the city. This is quite restrictive compared to peer cities. A potential change here could include altering the current 6.3-2.A Dimensional Table to allow 40’ of height for multifamily buildings in R-2 (similar to R-3). Alternatively height limits in both R-2 and R-3 could be raised such as to 40’ and 50’ respectively

Tucson for Everyone has also been following the development of the 21st Century ROAD to Housing Act through it becoming law on July 11. We believe it presents several funding opportunities for the City to continue modernizing the UDC:

• §207 establishes a HUD pilot program to issue competitive grants to assist state, local, and tribal governments with implementing regional housing planning and community development activities, including coordinating housing development with transportation planning.
• §208 creates a competitive grant program for local governments and tribes that demonstrate measurable increases in housing supply, incentivizing reforms such as streamlined permitting, density bonuses, and zoning changes. The program is funded $200M annually for seven years.
• §209 provides grants to local governments and tribes to select and implement pre-reviewed housing designs (such as accessory dwelling units, duplexes, or townhouses) to streamline affordable housing construction over five years.

In addition to the three funding sources above, §107 directs HUD to publish best practices on both local and state levels that can be used to modernize local zoning frameworks. Through Code Tucson ‘26, Tucson has already identified several existing shortfalls in the UDC and begun the process of correcting them. We believe Tucson can position itself to receive further funding by growing its code revision project into an active and ongoing effort.

In "City of Tucson — You Look Like a Neuron to Me", Arizona artist Monica Aissa Martinez imagines Tucson as a living cell, equating various land uses to organelles that perform different functions in our body. We believe our city is a living thing, and our code should reflect that.