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P&Z denies special exemption for manufactured home and approves commercial site plan for Public Works office

City of Cody Planning, Zoning, and Adjustment Board · May 21, 2026
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Summary

After extended debate over whether a converted manufactured home should be treated as a manufactured dwelling or as a permanent commercial building, the board denied a special-exemption request for 119 19th Street and approved a commercial site plan for the Public Works Office, finding the structure no longer qualifies as a manufactured home for zoning purposes.

The board spent substantial time on May 21 considering a staff-requested special exemption to allow permanent commercial use of a converted manufactured home at 119 19th Street and whether the correct review path was a special exemption or a commercial site plan.

Staff told the board that although significant code upgrades were completed, city staff recommended the special-exemption process to preserve notice and public comment procedures. A letter from the building official, Sean Collier, was provided to the board explaining that from a building-code perspective the structure meets B (business) occupancy standards but that the underlying structure remains a manufactured building by definition. Sean Collier testified that many of the changes (ADA-compliant bathroom, ramp, exterior stairs, parking and hard surfacing) were completed so the building can function as a business office while noting the structure could still be moved or sold in the future as a manufactured unit if removed from its foundation.

Board members split on the proper course: some said the upgrades removed the structure from the 'manufactured home' definition and urged proceeding by commercial site plan, while others emphasized code text and precedent and favored the special-exemption route for public notice. The board ultimately voted to deny the special-exemption request — finding there was an alternative path (commercial site plan) and that the board could make a finding the structure has been removed from the manufactured-home definition — and then approved the commercial site plan for the City of Cody Public Works Office Building at 119 19th Street with the explicit finding that the structure no longer qualifies as a manufactured home for zoning. The motions and votes were recorded on the meeting minutes.