Draft Unified Development Code (UDC)

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The lower Rattlesnake's proximity to downtown and to UM support the entire area from Lolo Street south to I-90 being designated U-R3 and U-R4. The area from Lolo Street to Mountain View from Gilbert to Rattlesnake Drive, and the adjacent est side of Rattlesnake Drive should be designated mixed use to support a future village center character.

As a resident of the Rattlesnake, I support higher density housing. We need to grow up and not out to preserve our open space.
Also as a parent, I would like to see more families able to live in the rattlesnake. The rattlesnake is pricing out families. Providing a variety of types of housing should help with this.
I do agree with concerns expressed in other comments about parking and traffic on the already narrow lower rattlesnake streets. It is difficult to turn left onto and from Van Buren to side streets during rush hour. Consideration needs to be given for how to safely manage additional traffic. Additionally pedestrian and bike safety for traveling along Van Buren needs to be considered like better bike lanes and crosswalks.

Please do whatever is needed to promote denser development and affordable options. Grow up, not out. It's time to walk the talk and not give in to the nimbyism. I live in the rattlesnake and do not believe we should be somehow shielded from the city's growth.

The proposed UR-3 & UR-4 zoning for the lower Rattlesnake does not give adequate consideration to the existing complexion of the neighborhood and the preservation of the small-town neighborhood feel. The Lower Rattlesnake, unlike other areas proposed for high density housing, is constrained by access and existing limits for transportation and parking.
It is geographically separate from other residential areas and has a historical significance for Missoula history and development. It is a mixture of single-family residences, and some duplexes or townhomes, but it retains the feel of a close knit neighborhood, lined on either side by maple or Box elder trees. It is hard to imagine 50’ high multi unit apartment complexes added to the neighborhood and still maintain the closeness and convivial nature of the Lower Rattlesnake
We were told that this high-density requirement comes from the state legislature and that the city must adhere to it, however the city does have options on where those high density zones are located. They are primarily in the middle of town and the lower Rattlesnake – not Grant Creek?
Walkability and bikeability are listed as critical factors in those decisions. When asked at the open house how the parking would be dealt with, the gentleman said they were assuming the tenants of the apartment complexes would walk or bicycle. That is a large assumption. How many Rattlesnake residents will be actually be walking and biking downtown to work and shop? Missoula is spread out through out the Clark Fork Valley with popular drainages in all directions for hiking, climbing, rafting etc which require transportation, which translate to cars that need parking. Typically we should assume 1 car per household – 2 is not unusual.
Lower Rattlesnake is particularly congested; streets on the Lower Rattlesnake, with the UR4 High Density zoning are particularly challenged. These streets ( Vine, Poplar, Cherry, Elm, Locust etc are essentially one lane streets with parking on either side of the street, you frequently need to pull into parking spaces to let traffic from the other direction by. Trying to get onto Van Buren from one of those streets can be challenging, with heavy traffic from both directions. The roundabout can be ineffective depending on the time of day and activities in Missoula. Rush hour traffic, Griz games or concerts make it a one-way stream of traffic coming off the interstate or backing the interstate traffic onto the expressway.
The Zoning presentations read that parking would be left to the discrimination of the builders, regarding whether they would include parking in their construction plans or not. Again, this is an assumption, an assumption that the builders will build in the best interest of the city – not in the builder’s interest? If builders take the less expensive route and leave out parking considerations, that puts the parking on the street in competition with existing homes for on-street parking. Additional retail development, coffee shops, hair cutters etc. would further compromise parking. This type of development will lead to the overpricing of small homes or vacant lots in the Rattlesnake for developers to create multi million dollars complexes.
Emergency services, fire suppression etc would be complicated by the increase in residents crowded into the Rattlesnake drainage, with narrow streets filled with parked cars. Wildfire from either up the canyon, or on Mount Jumbo could compromise escape routes if they are congested with dozens of apartments complexes filled with 2-4 or more people now fleeing as well.
Greenough Park is a gem in the lower Rattlesnake that is seeing increased use and impact from our increasing population. The riparian vegetation, the creekside, the birds and other wildlife are all impacted, with obvious implications from the additional impact from an exponentially increasing population with multi-unit apartment complexes.
Mount Jumbo with its popular trail to the L is an important wildlife zone, a potential wildfire and even avalanche zone. There are wildlife concerns, erosion concerns, avalanche concerns, many dogs on or off leashes and their contributions to the trail system concerns.
I understand the need to increase available housing appropriately; it does not feel appropriate to have multi-unit apartment complexes interspersed with single family dwellings in the Lower Rattlesnake. Building hgt should be limited to 35’ as has been done in other cities like Minneapolis, and be limited to single family, duplexes or townhouses, based on height limits, # of units, & size of lot.. Building hgt allowances of 50’ for the Vine St/Poplar St area, as well as 40’ limits for the mid corridor of the lower Rattlesnake are excessive, the 50’ hgt allowances far exceeds standards for similar areas and are a contradiction to the neighborhood feel of the lower Rattlesnake.

I have lived for the past 10 years on the corner of Monroe and Poplar, directly accros from the Alpha East apartments. My house was designed by AG Gibson, the same architect that built the Missoula Court house and many original buildings on the UM Campus. This is a part of the Lower Rattlesnake Historic District, of which one of the jewels is Greenough Park. The family that lived in my house for multiple generations ran the Hughes Brothers Farm in the Hell Gate valley, this probably contributes to the designation of Missoula as "The Garden City". The neighborhood is one of the most intact and deserves preservation for the cultural identity of Missoula.

I have had multiple instances of problems with the Alpha East apartments, including property damage due to contractors plowing their snow (for years!) into salty mountains on my property, a hit-and-run of my truck where the person drove right to their apartment across the street. Vehicles, RV's, boats, motorcycles parked literally for years without moving both in the lot and on all the surrounding streets, constant abandoned vehicles, drug busts, domestic violence, etc.

Now the proposal is to create U-R3 High Density housing with huge buildings in a historic neighborhood, completely changing the historic character of the neighborhood, increasing traffic and declining quality of life for residents who have made their home in the Lower Rattlesnake. This is a bad proposal for Missoula and the historical preservation of what still exists in Montana. Protect the Lower Rattlesnake from high-density housing!

Dear City Planning Staff,

Preserve Historic Missoula (PHM) would like to take this opportunity to comment on the City of Missoula’s Draft Unified Development Code. PHM is a local nonprofit organization dedicated to advocacy and education for all things historic in Missoula. We commend the City and its staff for the tremendous effort involved in putting together this document and propose the following changes in regard to historic preservation using the expertise of our broadly experienced and degreed board.

Our first major comment is concerning the public review process for Historic Preservation Permits. The public notice and engagement portions of the UDC are ill-defined and seemingly do away with the ability to participate in-person in a public forum. Now that the Historic Preservation Commission will not be operating with the same regulatory capacity, we recognize that this may need to change from how it is currently carried out. We would like to see opportunity for public comment and applicant presentation in a public forum to be included in the UDC, whether it remain a part of HPC meetings or part of the new Planning Commission meetings or another venue. Please include additional language clarifying how notice will be given for HPPs and how public comment can be submitted.

Our second major comment is regarding the designation of Historic Resources. Currently, the UDC only recognizes sites individually listed on the National Register of Historic Places, sites individually listed on the Missoula Inventory of Historic Resources, or sites within a Historic Resource Overlay as needing to go through the Historic Preservation Permitting process. This excludes all sites that are not individually listed within National Register Historic Districts. This oversight exempts a large number of historic sites in the city, including many downtown. PHM suggests that either all contributing resources within National Register Historic Districts are included as being required structures for HPPs or that all National Register Districts become HROs with the adoption of this code to ensure that modifications to our city’s important historic resources are reviewed appropriately.

Our third major comment is relative to general conformance of new construction, alterations, etc. within historic districts. We recognize that constraints on building height, density, setback, etc. have generally been lessened to encourage various types of development in the many new and reconfigured zones in the city. We also hope that requirements regarding form, mass, scale, and general conformance with the streetscape within historic districts and HROs can help guide this development in ways that respect the existing fabric. This is where it is vital to ensure that primary character defining features of neighborhoods are listed within the aforementioned missing HROs.

Our final major comment is regarding demolition by neglect. The writing of this UDC is an important opportunity to create a stronger path to the City’s enforcement of its prohibition of demolition by neglect in 4.6.04-S. We propose adding the following language to the end of this section: “Demolition by neglect will be considered demolition without a permit as referenced in 4.6.04-C.”

A handful of minor comments and questions follow that may help bolster language and intent of the UDC:

Chapter 2
2.1.04-A. Appointment
Consider adding a minimum amount of full-time experience in any of the areas listed.

Division 2.1.03 Planning Commission
How can/should the Historic Preservation Commission and Planning Commission interface? How can the interests of preservationists be ensured to have a voice on this commission? A potential solution could be that the Chair of the HPC would have a seat on the Planning Commission.

Chapter 4
4.6.03-D & 4.6.04-D Application Filing Fees
PHM would encourage some sort of scale or threshold for filing fees. Fees should not be seen as a barrier to alterations to a historic building, especially for small projects such as a porch or addition by a homeowner. That said, larger development projects that create applications with hundreds of pages create significant strain on City staff. Perhaps fees are only applicable to projects over $100,000 in cost.

4.6.08-C Establishment of an Historic Resource Overlay (/HRO)
Preserve Historic Missoula encourages the continued development of additional HROs to further protect the city’s historic resources. Existing National Register Historic Districts should be included as soon as possible to protect our important historic sites.

Chapter 5
Section 5.2.01-H. Natural, Cultural, or Historic Features
Consider adding at the end of this section: “including from loss of viewshed.” This introduces important specificity to protect cultural landscapes and preserve their historic settings.

Chapter 6
Are there ways in which infrastructure improvements might affect historic resources? There are no mentions of “historic” anywhere in this chapter. Some resources, such as the Orange Street Underpass, which is listed on the National Register of Historic Places, are themselves infrastructure.

Chapter 8
Consider adding some definitions from 4.6.02 including Historic Resource, Landmark, and others used outside of 4.6.02.


Thank you for your consideration of these comments.

Signed by the Board of Preserve Historic Missoula
Jared Schmitz, President, Josie O'Meara, Treasurer, Kayla Blackman, Secretary, Dan Hall, Jennifer Anthony, Page Goode, Rob Henry, Maggie Luthin, Alan Noonan, Skylar Rispins, Bea Williams, Dani Brown

The thing that is most striking about the zoning plan which will go to the City Council in December is how quickly and shamelessly it is being rammed through. The original document which it supposedly supports, The Missoula 2045 Land Use Plan, is a long and carefully written plan for Missoula’s future based on years of study and public input. The plan contains important goals for future land use for Missoula which are ignored completely in the knife-edged zoning plan which seeks only to build as many additional housing units as possible. One example is Policy Objective #4, Identify historically and culturally sensitive places and landscapes. This critical goal states, “Missoula is grappling with significant challenges in preserving its historic and culturally significant sites, which are essential for understanding Missoula’s story and maintaining community identity…. Historic preservation is vital for maintaining cultural identity and continuity of communities. By preserving and cherishing our historic sites, we honor our past, enrich our present, and secure our future.” In 1999, the National Park Service and the Montana State Historic Preservation Office officially designated 20 blocks of the Lower Rattlesnake as a Historic District in the National Register of Historic Places. These 20 blocks—from Pierce to Monroe (East-West) and Elm to Vine (North-South)—align with Policy Objective #4. One of eleven historic districts in Missoula and consisting of well-maintained working-class homes which were built primarily between 1900 and 1950, this area deserves recognition and protection. But it does not receive recognition or protection in the proposed zoning plan. Eighteen of the twenty blocks are scheduled to be zoned high density. Three of the blocks are to be U-R4, which allows four-story apartment buildings with no maximum number of units. It is disingenuous in the extreme to rhapsodize about historic preservation while putting a bulldozer target on the back of an area already designated historic. The zoning plan is an imperfect plan that will disfigure our beautiful city permanently. The decision to adopt it needs to be delayed and the period for public comment needs to be extended. The plan needs work! Historic areas like the Lower Rattlesnake need to be preserved and not used simply as acreage to put high density housing.

After last night's code reform public meeting, I was wondering how Missoula's code reform proposals compared to other cities of similar size. I asked Gemini and got some great information, although of course the numbers should be double-checked. Here is the full conversation log for reference: https://gemini.google.com/share/f3709d892960

And here is my (still rather long) summary of the highlights:

Minneapolis (with a significantly larger population of ~400k) is the only example old enough to have real results data about the effect of upzoning on housing affordability. Studies showed that prices increased in the short term but then moderated to slower growth than comparable metro areas, especially for rents. The zoning changes increased height limits to 28-33' (extra allowance is for pitched roof only) for most single-family residential districts and was criticized for not increasing FAR/lot usage enough in those districts (only at 0.5 FAR). Neighborhoods with strong transit were upzoned further.

Two examples with more comparable size to Missoula are Walla Walla, WA and South Bend, ID; both happened too recently to generate reliable affordability data. However, it's notable that both rely on form-based approaches that do not use FAR, instead just using height limits, unit counts, max lot coverage, and setbacks. They both capped height in single-family residential neighborhoods to 35 feet.

Applying this data to Missoula and specifically the Lower Rattlesnake which I know the best as my own neighborhood:

The Lower Rattlesnake has very poor transit connectivity, with one bus line that runs only once per hour. This bus has been totally empty the few times I've taken it, and a recent handout at the city neighborhood council meeting noted that 100% of households have at least one car, which tracks with the poor transit access. Walking/biking access is also unreliable, even in the summer months, due to frequent train track obstructions along the most pedestrian/bike-friendly route (the unobstructed alternate route requires, biking through two roundabouts with tons of cars, biking on the sidewalk right next to pedestrians, or walking 1+ mile to access downtown). Moreover, many streets are lacking continuous sidewalk access, including Jackson St despite its designation as a neighborhood greenway.

Although the neighborhood has one large apartment building on the southwestern edge, this building form is itself out of character with the rest of the neighborhood, which consists of a mix of a single-story and two-story single-family homes or duplexes. Notably, the apartment building is reasonably close to downtown only if a train is not blocking Greenough Drive; detouring as a pedestrian turns a 16-min walk into a 23-min walk (from 0.7 miles to 1 mile; for reference, a "walkable" distance is typically defined as between 0.25-0.5 miles). An infrastructure solution to the train obstruction problem (e.g. building an underpass or overpass) has been estimated to cost over $10M for just one intersection.

Most of the Lower Rattlesnake is proposed to be zoned as UR-3, with a few blocks around the apartment building -- closest to the problematic, often-train-obstructed road access -- zoned as UR-4. UR-3 allows a max building height of 40ft, while UR-4 allows a max building height of 50ft. These height changes far exceed the prior examples from comparable cities like Walla Walla and South Bend (both capping single-family residential neighborhoods to 35ft) and even larger cities like Minneapolis, which only exceeded 33ft max height for neighborhoods with strong transit connections.

When I asked a staff member at a recent code reform forum about the rationale behind these increased height limits, they pointed out that Missoula's use of FAR restricts the realistic "penciling out" height that a new development could take. I have been unable to find information about what "realistic" resulting building heights might look like given an average lot size (e.g., 8000 sqft) and proposed zoning in my neighborhood. Instead of continuing to rely on FAR in a complex calculation, why don't we simplify our zoning code -- one of the original goals! -- by relying solely on a combination of max height, unit count, lot coverage, and setbacks to control form while allowing for increased density? This is the zoning philosophy taken by both Walla Walla and South Bend, and it seems more appropriate for smaller cities with majority single-family residential neighborhoods.

In conclusion, I agree with an earlier commenter who supports increased housing density throughout Missoula but urges that the Lower Rattlesnake -- and other neighborhoods that also have poor transit connectivity coupled with mostly two-story or lower homes -- be zoned as UR-2 or below (max height of 35ft). I also urge the city to consider scrapping FAR entirely and switching to a simpler, form-based zoning control system, as was suggested as early as last year by multiple public comments at prior community meetings that I attended regarding the code reform.

City of Missoula – Draft Zoning Framework – AARP MT Review and Recommendations

Thank you for the opportunity to provide input on the City of Missoula’s Draft Zoning Framework. AARP Montana appreciates the city’s efforts to modernize zoning in ways that support housing diversity, affordability, accessibility, and livable communities for residents of all ages. Below are our observations and recommendations based on AARP’s policy priorities:

1. Housing Diversity and Choice
The Missoula Unified Development Code establishes a range of residential zoning districts (Rural, Limited Urban, Urban) and mixed-use districts, each with specific standards for housing types, density, and building form. The code allows for a variety of housing types, including single-family homes, duplexes, cottage courts, rowhouses, and apartment buildings. Higher-density options and “missing middle” housing are supported in urban and mixed-use districts. The code also provides for accessory structures and neighborhood commercial buildings, which can enhance neighborhood vitality and walkability.

AARP advocates for a broad range of housing options to meet the needs of people as they age, including affordable, accessible, and diverse housing types. The code’s support for housing diversity, including smaller-scale infill, multi-unit buildings, and accessory structures, aligns with AARP’s emphasis on “aging in place” and the need for housing that accommodates changing household sizes and needs.

2. Affordability and Accessibility
The code promotes housing affordability by enabling higher densities in urban and mixed-use districts, supporting infill and redevelopment, and allowing for a range of building types. There are provisions for group living, single-room occupancy, and community residential facilities, which can serve older adults and people with disabilities. Parking requirements are reduced or exempted in certain districts, which can lower development costs.
AARP policy calls for affordable housing options, especially for older adults on fixed incomes. The code’s flexibility in density, building types, and parking supports affordability. The inclusion of group living and single-room occupancy options is consistent with AARP’s advocacy for housing that meets the needs of older adults and people with disabilities.

3. Neighborhood Stability and Integration
The code emphasizes context-sensitive development, neighborhood stability, and integration of new housing into existing patterns. Standards for setbacks, lot widths, building heights, and landscaping are calibrated to maintain neighborhood character while allowing for growth. Mixed-use districts encourage integration of residential, commercial, and civic uses, supporting vibrant, walkable neighborhoods.

AARP supports policies that foster stable, integrated neighborhoods where people of all ages can thrive. The code’s approach to context-sensitive development and integration of uses aligns with AARP’s vision for “livable communities” that are safe, walkable, and socially connected.

4. Accessibility, Universal Design, and Safety
While the code sets standards for building form, placement, and landscaping, it does not explicitly reference universal design or accessibility features in residential buildings. However, it does allow for group living facilities and requires handicap accessibility in certain overlay districts (e.g., Marshall House Historic Resource Overlay).

AARP strongly advocates for universal design and accessibility in housing, enabling people to remain in their homes as they age. The code could be strengthened by more explicit requirements or incentives for accessible/adaptable housing features in all districts.

5. Transportation Choice and Walkability
The code advances walkability by tying ADA-aligned frontage improvements to development, adopting Street and Trail Type maps that operationalize complete streets, and requiring connected street networks with short blocks. It limits drive-throughs in walkable districts, requires both short- and long-term bike parking with clear siting standards, and reforms parking with reduced or zero minimums in key areas plus additional reductions near frequent transit. It also advances transit-supportive development patterns, especially in urban and mixed-use districts.

AARP advocates for making walking and rolling an easy choice, biking secure and convenient, and transit a practical default – particularly for older adults and people with disabilities.

Recommendations for Further Alignment with AARP Policy and potential gaps

1. Accessibility and Universal Design
• The code does not explicitly require universal design or accessibility features in all residential buildings.
• While accessibility is required in some overlay districts, broader requirements or incentives for accessible/adaptable housing are not specified.
• This could limit housing options for older adults with mobility or sensory impairments.

2. Affordability
• The code supports affordability through density and flexibility, but does not mandate affordable housing or provide specific affordability incentives.
• Older adults on fixed incomes may still face barriers to finding affordable housing without additional affordability requirements.

3. Support Services Integration
• While mixed-use districts allow for integration of services, the code does not specifically address the proximity or availability of health care, social services, or age-friendly amenities.

4. Transportation Choice and Walkability
• AARP recommends prioritizing improved pedestrian safety at mid-block locations. Where block lengths approach the maximum, require well-marked, ADA-compliant mid-block crossings with daylighting, tighter curb radii, shorter crossing distances, and traffic-calming design to lower turning speeds and enhance safety for people walking and rolling - especially older adults and people with disabilities.

Thank you for your consideration.

Regards,
Kristin Page-Nei, AARP MT Government Relations Director