Cibolo planning commission recommends denying proposal to loosen platting rules and allow manufactured homes by right in agricultural zones

The Cibolo Planning and Zoning Commission voted Wednesday night, July 30, 2025, to recommend denial of a proposed amendment to the city's 2024 Unified Development Code that would lower the platting exemption from 5 acres to 2.5 acres and allow manufactured homes by right in areas zoned agricultural (AG).

The change under consideration would also set a limit of three dwelling units per tract (including manufactured homes) allowed by right on properties up to three acres and offered two narrower geographic options that would limit the by-right allowance to AG properties south of FM 78 or to AG properties south of FM 78 and east of Santa Clara Road. The commission's recommendation followed a public hearing, a staff presentation, and an executive session.

City staff presented a preliminary draft of an ordinance amending UDC sections 20.19 (platting not required), 20.30.17 (development plats), Article 13 (use tables) and Article 14.1 (lot design standards). The staff presentation said the city council unanimously asked the city manager to initiate the amendment, and staff supplied a second draft that incorporated options discussed between staff and the commission chair and vice chair. The draft would make manufactured homes permitted (a "P" use) in the AG district rather than allowed only by conditional use permit (CUP), while keeping the CUP requirement in single-family 1 (SF-1) zoning.

Staff also described two geographic options: Option 1 would apply the amendment only to AG properties south of FM 78; Option 2 would apply only to AG properties south of FM 78 and east of Santa Clara Road. Staff displayed a map showing AG parcels and a color legend used to indicate which properties would be exempt from platting under the lower acreage threshold.

During public comment, resident and agricultural landowner Carol Latimer urged the commission to consider the effect on legacy landowners who want family members to live on their property. She said the draft changes could be helpful for multigenerational families but warned the proposal as written risked "a complete and total loss of oversight by the city" because allowing manufactured homes by right would bypass CUP review, neighborhood input and design or infrastructure conditions. "The buy right manufactured housing eliminates case by case review through CUPS with no neighborhood input or conditions," Latimer said. She also noted a personal parcel size of 31.54 acres and urged commissioners to preserve agricultural zoning intent.

Latimer cited Texas Local Government Code section 232.0015(e) (as read during the hearing) and said that county-level exemptions tied to family relations and agricultural valuations were more restrictive than the proposed city change. "Cutting the exemption threshold in half is within the city limits in the ETJ where infrastructure expectations are going to be much higher," she said.

Commissioners and staff raised practical concerns about infrastructure and public safety. Fire Chief Troncoso confirmed there is a fire hydrant near the parcel that motivated the amendment request and said he measured a driveway distance of 224 feet from that hydrant to the driveway in question. Commissioners asked whether the proposed change would create unregulated density, unsafe driveway access, drainage or septic issues and whether it would encourage piecemeal land division that undermines long-term planning.

Several commissioners said they found no clear justification in the record for lowering the exemption from 5 acres to 2.5 acres. Commissioners referenced the city's recently updated comprehensive plan and said the existing UDC better supports the plan and the city's infrastructure expectations. The chair emphasized the commission's advisory role and the amount of research and outreach typically required before altering zoning-related standards.

After discussion and an executive session, Commissioner Hebron made a motion that the Planning and Zoning Commission recommend denial of the proposed UDC changes (the motion text: "Planning and Zoning Commission recommends that we recommend denial to the change of the UDC within zoning for the exemption of planning based on UDC section 3.7 d 4. There is no other criteria which, at the discretion of planning and zoning commission, are deemed relevant and important in the consideration of the change to the amendment."). The motion was seconded; a roll-call vote followed and the chair stated the motion carries.

The commission did not adopt any amendments to the draft ordinance at the meeting. The staff presentation, public testimony and the commission's deliberations all occurred during the July 30 public hearing and action item on the UDC amendment.

The Planning and Zoning Commission's recommendation record and the draft ordinance will be part of the official file forwarded to the city council for its consideration as the legislative body, consistent with the commission's advisory role.