PRESENTER: Presenter
Applicant: Sun Communities Operating Limited Partnership
Owner: Sun Silver Star LLC d/b/a Sun Retreats Texas Hill Country
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SUBJECT: Title
SUP26-256 Public hearing and recommendation to City Council, requested by Sun Communities Operating Limited Partnership, on behalf of Sun Silver Star LLC d/b/a Sun Retreats Texas Hill Country, to rezone approximately 11.44 acres out of the Yogi Bears Jellystone Park, Block 1, Lot 2, from C-3 (Commercial District) to C-3 SUP (Commercial District with a Special Use Overlay to allow manufactured homes), currently addressed at 141 Rueckle Road.
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DEPARTMENT: Neighborhood and Community Planning
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COUNCIL DISTRICTS IMPACTED: 1
BACKGROUND INFORMATION:
Case No: SUP26-256
Applicant: Sun Communities Operating Limited Partnership
Owner: Sun Silver Star LLC d/b/a Sun Retreats Texas Hill Country
Staff Contact: Mary Lovell, (830) 221-4051, mlovell@newbraunfels.gov
The subject property is approximately 11.44 acres located along the east side of Rueckle Road approximately one-quarter of a mile south of Interstate Highway 35. Surrounding and nearby zoning districts include APD (Agricultural Pre-development District), M-2A (Heavy Industrial District), MU-B (High Intensity Mixed Use District), C-3 (Commercial District), C-1B (General Business District), and R-2 (Single-Family and Two-Family District). Surrounding land uses include residential, commercial, and undeveloped property.
ISSUE:
The applicant is requesting a zoning change from C-3 (Commercial District) to C-3 SUP (Commercial District with a Special Use Overlay) to allow manufactured homes as an additional allowed use on the subject property. The applicant indicates that the rezoning request is intended to restore a use (manufactured homes) that previously existed on the site but is no longer allowed under current zoning regulations.
The applicant has stated that, in addition to the traditional RV park use, there were previously ten manufactured homes on the property until sometime in 2024. In 2024, the ten manufactured homes were sold and removed because they were older models that were deteriorating.
Prior to a 2012 zoning code update (Ord. 2012-49, approved by City Council September 10, 2012), manufactured homes were an allowed use in the C-3 zoning district. With the adoption of the aforementioned 2012 code amendment, manufactured homes were removed from the list of allowed uses in C-3, causing the existing manufactured homes to become legal nonconforming uses. Under the City’s nonconforming uses and structures provisions set forth in Sec. 144-2.3(d)(3), nonconforming uses and structures may continue; however, if such use is discontinued for a continuous period exceeding twelve months, it may not be reestablished.
Since the property owner removed all manufactured homes from the site for more than twelve months, this resulted in a loss of the manufactured homes’ legal nonconforming status. The applicant states the current property owner of the RV Park was not aware that the current zoning of C-3 no longer allowed the use of manufactured homes on the property.
Beginning in May of 2026, the owner began placing manufactured homes in the spots where the previous manufactured homes were located and applying for building permits. During the building permit review process, staff notified the applicant that manufactured homes are no longer allowed in the C-3 zoning district.
To retain the units and proceed with permitting, the applicant is now seeking a rezoning to C-3 SUP (Commercial District with a Special Use Overlay to allow manufactured homes), which would maintain all uses currently allowed within the C-3 district and add manufactured homes as an additional approved use through the Special Use process. Approval of this rezoning request would legalize the manufactured homes recently placed on the property and allow their continued permitting and use. A denial of the request would require the removal of the manufactured homes.
Traffic Impact Analysis (TIA): Only a TIA worksheet is required, since the use would generate fewer than 99 peak hour trips.
Drainage: Per adopted ordinance, if a drainage study is required, it will be conducted with the future Public Infrastructure Construction Plan approval process and/or Building Permit stage, as applicable.
COMPREHENSIVE PLAN REFERENCE:
A request to allow manufactured homes in the C‑3 (Commercial District) would not be consistent with the following actions from Envision New Braunfels:
• Action 1.5: Promote economic centers by ensuring adequate parking for people to visit businesses, restaurants, and shops. (This Action reinforces the corridor’s intended commercial purpose and prioritizes commercial and mixed-use activity over singular residential uses.)
• Action 1.8: Concentrate future investment in industrial and employment centers along high‑capacity transportation networks such as IH‑35. (Manufactured homes introduce a low‑intensity residential use that conflicts with the commercial/employment‑focused nature of designated corridors.)
• Action 1.11: Update policies and codes to achieve development patterns that implement the goals of this plan. (The plan’s development pattern emphasizes preserving commercial corridors for economic activity rather than residential encroachment.)
• Action 1.13: Use funding tools to support commercial façade grants and reinvestment. (Commercial and mixed-use reinvestment is the intended future pattern in these corridors; allowing manufactured homes moves away from this direction.)
• Action 3.3: Balance commercial centers with stable neighborhoods. (This action supports keeping commercial areas from negatively impacting residential, while still supporting mixed-use.)
A request to allow manufactured homes in the C‑3 (Commercial District) could be considered consistent with the following actions from Envision New Braunfels:
• Action 1.6: Incentivize infill development and redevelopment to take advantage of existing infrastructure. (This action supports reuse of previously developed sites, which can include the reintroduction of manufactured housing where it was previously located.)
• Action 3.13: Cultivate an environment for a healthy mix of different housing products at a range of sizes, affordability, densities, amenities and price points across the community. (This action supports flexibility in offering diverse housing types, sizes, and affordability levels.)
• Action 3.15: Incentivize home development that is affordable and close to schools, jobs, and transportation. (This action reinforces the value of housing proximity to employment and services, which could align with housing located in or near commercial corridors.)
• Action 3.16: Review and revise regulations that inadvertently inhibit creative housing options or workforce housing alternatives. (This action supports regulatory flexibility for nontraditional or more attainable housing formats.)
• Action 3.17: Allow for neighborhood‑scale commercial within walking distance of homes. (This action proposes an integrated pattern of residential and commercial uses in close proximity, where appropriate.)
• Action 3.30: Encourage and incentivize workforce/affordable housing. (This action supports housing attainable to workers and lower‑income households, aligning with traditionally low‑cost housing types such as manufactured homes.)
• Action 3.31: Adopt policies and ordinances supportive of workforce housing. (This action further promotes regulatory support for attainable housing production.)
Future Land Use Plan: The subject property is located within Walnut Springs Subarea, near existing Education and Civic Centers and near future Market and Employment Centers.
STRATEGIC PLAN REFERENCE:
• Economic Mobility - Output: Increase the number of new affordable housing units produced each fiscal year.
• Economic Mobility - Objective: Incentivize mixed-use developments and redevelopments in targeted locations to create a built environment with integrated housing, commercial centers, and opportunities for improved connectivity.
FISCAL IMPACT:
The proposed request, if approved, supports Land Use Fiscal Analysis goals by prioritizing infill development that adds people and buildings in areas with existing infrastructure, increasing tax revenue without significant additional impacts on services or infrastructure costs and distributing cost burdens across more homes and business owners.
Recommendation
RECOMMENDATION:
Denial. While staff acknowledges several actions within Envision New Braunfels that support housing diversity, workforce housing, and flexible residential types, these supportive policies are balanced against several actions that similarly prioritize commercial corridor preservation. The predominant direction of the Comprehensive Plan leans toward preservation of commercial uses in C-3 corridors due to the intensity of uses allowed in this zoning district.
If City Council were inclined to approve the requested rezoning, staff recommends the following conditions:
1. No more than 10 manufactured homes are allowed to be permitted on the property.
2. A screening fence is required along any street frontage adjacent to any manufactured home.
3. All manufactured homes must adhere to the development standards set forth in Appendix B, Mobile Home Communities, as well as all other city building codes as applicable.
Code of Ordinances Sec. 144-2.1 Changes and Zoning Amendments:
(b) Considerations for approving or denying a zoning change. In making a determination regarding a requested zoning change, the planning commission and the city council shall consider the following factors:
(1) Whether the uses permitted by the proposed change will be appropriate in the immediate area concerned, and their relationship to the general area and to the city as a whole;
(2) Whether the proposed change is in accord with any existing or proposed plans for providing public schools, streets, water supply, sanitary sewers, and other utilities to the area;
(3) How other areas designated for similar development will be, or are likely to be, affected if the proposed amendment is approved;
(4) Any other factors that will substantially affect the public health, safety, morals, or general welfare; and
(5) Whether the request is consistent with the comprehensive plan.
Mailed notification as required by state statute:
Public hearing notices were sent to owners of 19 properties within 200 feet of the request. As of the date this agenda was posted, three responses were returned in favor (58%) and zero responses have been received in opposition. A supermajority vote of City Council is not required to approve the applicant’s request.
Resource Links:
• Chapter 144, Sec. 3.3-9 (C-3) of the City’s Code of Ordinances: <https://library.municode.com/tx/new_braunfels/codes/code_of_ordinances?nodeId=PTIICOOR_CH144ZO_ARTIIIZODI>
• Chapter 144, Sec. 3.6 (SUP) of the City’s Code of Ordinances: <https://library.municode.com/tx/new_braunfels/codes/code_of_ordinances?nodeId=PTIICOOR_CH144ZO_ARTIIIZODI_S144-3.6SPUSPE>
• Appendix B, Mobile Home Communities: <https://library.municode.com/tx/new_braunfels/codes/code_of_ordinances?nodeId=PTIICOOR_APXBMOHOCO>