Growth and City Form Policy Paper
April 7, 2016
Prepared by:
Economic & Planning Systems
MIG, Inc.
Growth and City Form Policy Paper
April 7, 2016
Prepared by MIG, Inc.
Table of Contents
1
Executive Summary ................................................................................................................. 1
2
Introduction ............................................................................................................................... 5
3
4
2.1
What is a Comprehensive Plan? ............................................................................ 5
2.2
Context and Purpose ............................................................................................... 5
2.3
San Antonio’s Comprehensive Planning Process ................................................ 6
2.4
Overview of the Policy Papers ................................................................................ 8
2.5
The Growth and City Form Policy Paper ............................................................... 8
Challenges, Opportunities and Key Issues ........................................................................... 9
3.1
Introduction and Overview: .................................................................................... 9
3.2
Assets, Challenges and Opportunities: ................................................................. 9
3.3
Key Issues .................................................................................................................. 19
Key Strategies and Lessons Learned .................................................................................. 20
4.1
Directing growth while protecting critical natural resources .......................... 20
4.2
Encouraging forms of development that will help the City achieve its stated
goals in other Plan elements. ............................................................................................... 25
5
6
Recommended Goals and Policies .................................................................................... 27
5.1
Growth and City Form (GCF) Goals .................................................................... 27
5.2
Growth and City Form (GCF) Policies ................................................................. 28
Next Steps ................................................................................................................................ 31
1 Executive Summary
To be successful and truly address the long-term issues facing San Antonio, the
Comprehensive Plan has to tackle the difficult questions that arise from an honest
assessment of the City’s challenges and clearly state the hard choices residents must
make to achieve the community’s vision for the future. Many of these hard choices are
rooted in the fact that a “business as usual” approach is yielding systems and patterns
that are unsustainable or that produce results counter to the goals of the plan.
Reversing decades-old habits and changing entrenched systems is difficult. The
uncertainty and complexity associated with planning for the next 25 years is daunting.
This series of policy papers attempts to help surmount these challenges by providing
thorough analyses of the important issues, potential solutions, and policy implications
relating to key elements of the Comprehensive Plan. This paper focuses on a range of
topics associated with how and where the City of San Antonio grows over the next 25
years, as well as the potential implications of that growth.
The Growth and City Form policy paper was developed through the synthesis of several
efforts and studies related to the Comprehensive Plan effort, and from the insight and
guidance provided by the Growth and City Form Plan Element Working Group. The
policy paper begins by providing context on the purpose and its role within the
comprehensive planning effort. This is followed by a summary of the City’s assets,
challenges, and opportunities relating to growth and urban form, as well as the
identification of key issues that inform the development of the Goals and Objectives,
and Policies which are provided at the end of the paper. San Antonio has several
assets relating to growth and urban form including:
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Forecasted demand for new jobs and housing;
Strong core of economic drivers (military, healthcare, education, and tourism);
Unique economic differentiators (proximity to the Eagle Ford shale formation
and sea ports in Houston and Corpus Christi);
Low cost of living and high quality of life;
Historic neighborhoods;
High quality of schools (in some areas);
Substantial capacity for infill development throughout most of the city; and
A number of large, potentially transformational development projects
(Hemisfair, Brooks City Base, Port San Antonio and the Texas A&M San Antonio
Campus and associated development).
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These assets provide San Antonio with numerous options for guiding growth and city
form in the city in a new and more sustainable direction. However, the city does have
significant challenges that have to be addressed. These challenges are posed as
question below to help shape the policies included in this paper.
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How will San Antonio accommodate the half a million new jobs and households
forecast to locate in Bexar County?
How can San Antonio utilize annexation strategically as part of a larger toolbox?
Where in the city should higher intensity growth be directed and encouraged?
What forms of development will help the City achieve its stated Goals in other
Plan elements?
How can growth be managed in a way that respects and protects the city’s
natural resources, historical features, and cultural assets?
Which direction can and should growth go within the city given the decreasing
land supply in traditionally high growth areas (north and west)?
How can the City shift development momentum to areas that traditionally have
had limited demand for new development?
How should the provision of services from SAWS, CPS, VIA and others be
connected to the City’s growth plans?
Do the City and SAWS have enough water to serve future growth? Should the
City and SAWS direct growth through water provision policies and decisions?
Should San Antonio grow (more so) into counties other than Bexar?
How should San Antonio address development in unincorporated Bexar
County?
What is the City’s role in providing infrastructure for new development in
greenfield and annexation areas?
Two approaches for addressing these challenges are explored in more depth in the Key
Strategies and Lessons Learned section of this paper: 1) determining where growth
should be directed and encouraged and doing so in a way that protects vital natural
resources; and 2) encouraging forms of development that help the City to achieve
stated goals in other Plan elements. An examination of best practices and strategies
show the importance of a comprehensive planning process that engages an array of
stakeholders, multiple jurisdictions and communities in an effort to identify areas in a
region where growth should be encouraged and where it should be discouraged. With
these areas are identified, policies and regulatory techniques can be deployed that
incentivize development in the desired areas that are more sustainable from an
environmental and/or fiscal perspective. Such efforts are predicated on a new way of
thinking about growth that requires significant cooperation and coordination between
different jurisdictions, utilities and other members of the community at a citywide and
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regional level. The result allows growth to take place in ways that favor more compact
mixed use projects that are more compatible and consistent with the economic and
environmental goals of San Antonio and with the goals of individuals seeking a livable
community in which to live, work and play.
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The paper ends with a presentation of the goals and policies that were developed to
address these challenges and build on the City’s assets and greatest opportunities.
Eight proposed Comprehensive Plan Goals were developed for Growth and City Form.
The eight goals are provided below and the associated objectives policies (guidance
for future decisions and actions) are provided later in this paper. The proposed Growth
and City Form goals are:
GCF Goal 1:
Higher density uses are focused within the City’s 13 regional centers
and along its arterial and transit corridors.
GCF Goal 2:
Priority growth areas attract jobs and residents.
GCF Goal 3:
Strategic annexation benefits existing and future City residents and
does not burden the City fiscally.
GCF Goal 4:
Sustainable infill and mixed-use development provide walkable and
bikeable destinations for all residents.
GCF Goal 5:
Growth and city form support improved livability in existing and future
neighborhoods.
GCF Goal 6:
Growth and city form support community health and wellness.
GCF Goal 7:
Development practices avoid, minimize or mitigate negative impacts
on the city’s natural resources, water supply, water quality, surface
waterways, and air quality.
GCF Goal 8:
Students throughout San Antonio have enhanced educational access
and perform at a high level. (See also PFCS Goal 4)
These eight goals set the priorities for actions to be taken by the City and policies that
will direct City staff and decision makers for years to come.
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2
Introduction
2.1
What is a Comprehensive Plan?
The Department of Planning & Community Development (DPCD) is developing a
modern Comprehensive Plan for the City of San Antonio. A comprehensive plan is an
official, long range planning document that provides policy guidance for future growth,
development, land use, infrastructure and services. Texas Local Government Code
states that comprehensive plans “are for the purpose of promoting sound development
of municipalities and promoting public health, safety, and welfare.” (Sec. 213.001).
The purpose of a comprehensive plan is to unify the visions, goals and policies of the
City’s other plans and initiatives. It identifies specific issues, challenges and needs and
presents preliminary concepts, policies and recommendations for various elements of
the community. With an implementation strategy, measurable indicators and targets,
and actions items, the Comprehensive Plan provides strategic direction for decisionmaking and community investment.
2.2
Context and Purpose
It is important to review and update comprehensive plans periodically in order to meet
the changing goals and needs of a community. The City’s current comprehensive plan
is the 1997 Master Plan Policies. The primary objective in undertaking the current
Comprehensive Plan is to engage the community in the refinement and
implementation of the vision for growth and development in San Antonio established
by the SA2020 process.
The SA2020 vision originated with a series of
public forums in 2010 to develop goals for
improving San Antonio by the year 2020.
Thousands of San Antonians participated in the visioning process, which culminated in a
detailed report, released in 2011, that outlined a bold, strategic vision for San Antonio's
future. This vision reflects the community’s desire to support economic development
and new jobs while fostering community arts, education, health, and culture. The intent
of SA Tomorrow is to build upon that vision while also addressing those topical areas not
included in the SA2020 report that are also crucial to San Antonio’s future.
SA Tomorrow is the City’s innovative, three-pronged planning effort established to
implement the SA2020 vision, and includes three concurrent and complementary plans:
an updated Comprehensive Plan; a Sustainability Plan; and a Multimodal
Transportation Plan, all working in concert to guide the City toward smart, sustainable
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growth. Current projected growth for Bexar County is expected to reach 1.1 million new
residents, 500,000 new jobs, and 500,000 new dwelling units by 2040. This update to the
Comprehensive Plan is needed in order to prepare the City for this anticipated
population and employment growth and to help residents understand what that
growth can look like and how different types of growth will affect the functioning of the
City.
Bexar County Population Forecast, 2010 to 2040
With a relatively fixed area available for future development, how this population and
employment growth is accommodated impacts the City’s overall quality of life and its
livability. Planning now allows the City to direct growth according to the community’s
vision and other important goals. The goals of this project are to:
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2.3
Revise 1997 Master Plan Policies;
Re-affirm the community’s vision for the future;
Implement SA2020 vision for the built environment;
Articulate the form of future physical growth;
Accommodate and distribute projected population growth;
Guide strategic decision making – annexation, transportation planning, etc;
Guide infrastructure investments and incentives;
Reconcile existing plans, policies, and assumptions; and
Update the current city planning program.
San Antonio’s Comprehensive Planning Process
The Comprehensive Plan planning process commenced in the winter of 2014. The first
phase of the process was the development of the Existing Conditions Technical
Background Report which presents data and summaries of document and plan reviews
for each of the nine content-specific elements of the Comprehensive Plan.
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The SA Tomorrow Comprehensive Plan will address the following nine topic areas in the
form of unique plan elements:
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Growth and City Form;
Transportation and Connectivity;
Housing;
Community Health and Wellness;
Public Facilities and Community Safety;
Historic Preservation and Cultural Heritage;
Military;
Natural Resources and the Environment; and
Jobs and Economic Competitiveness.
Sustainability—economic sustainability, environmental sustainability and social equity—
are being integrated throughout the aforementioned policy areas. Inclusivity, housing
choice, economic development strategy, sustainability and equity are all issues
addressed in the rest of the Growth and City Form Policy Paper.
With the Existing Conditions Technical Background Report complete, the process shifted
toward policy analysis and recommendation. The existing conditions report, the
subsequent policy analysis, and several rounds of working group revisions informed a
framework of goals and policies for each plan element. Plan element goals and
policies were further refined in conjunction with a concurrent process of identifying and
developing “place types” that will help guide and shape growth, redevelopment, and
preservation in neighborhoods, employment centers, and major corridors throughout
the city. In the end, the goals and policies will reflect and support the community’s
vision and the key guiding principles that characterize the city’s ambitions for the next
25 years.
The final step will be to draft a new comprehensive plan specific to San Antonio that will
be adopted by the City Council. During the entire process, there is ongoing community
involvement and stakeholder input (including stakeholder interviews, Plan Element
Working Groups, neighborhood workshops, public meetings and other outreach efforts)
that will be woven into the final plan.
The Comprehensive Plan will be used as a guide for making official decisions regarding
growth and development. Specifically, the Comprehensive Plan will be used to provide
concrete goals and action to ensure strategic growth and the preservation of San
Antonio’s character, while improving quality of life for all.
The final section of the Plan will address strategies for the plan’s implementation.
Success in achieving plan goals will be measured by targeted indicators and
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implemented according to actionable policies. Indicators are measurable factors that
collectively provide insight on existing conditions and progress specific to each goal.
Indicators are the means of measuring movement toward or away from the goals. The
implementation section, including specific targets, benchmarks and actions will be
updated approximately every five years.
2.4 Overview of the Policy Papers
The policy papers are informed by comments and feedback obtained during multiple
rounds of Plan Element Working Group (PEWG) meetings held in San Antonio in May,
July, September, and December 2015, as well as several rounds of written comments
provided by working group members and City staff.
Each policy paper offers a concise presentation of relevant data points and themes
emerging from research and diverse community input. Each paper provides important
background context, summarizes existing programs and policies, and represents an
effort to link the findings emerging from the existing conditions research and community
input to the proposed goals and policies for six Comprehensive Plan topic areas.
The six working papers are:
1.
2.
3.
4.
5.
6.
Growth and City Form;
Housing;
Transportation and Connectivity;
Jobs and Economic Competitiveness;
Community Health, Public Facilities and Community Safety; and
Military.
2.5 The Growth and City Form Policy Paper
The development of the Growth and City Form Policy Paper builds on work and efforts
completed for the Comprehensive Plan process and by other City departments and
partners.
In addition to its own efforts, the City of San Antonio has several partners that impact
the future growth patterns of San Antonio. Some of the regional partner agencies
include:
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Alamo Area Council of Governments;
Alamo Area Metropolitan Planning Organization;
Bexar County;
VIA Metropolitan Transit; and
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Neighboring incorporated towns, cities and counties.
The issues addressed in this paper and the policies developed were formed using prior
research and analysis efforts and planning analysis completed specifically within the SA
Tomorrow process. Major efforts and reports that provide the technical analysis and
visioning that shaped the policies developed include:
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SA2020;
Comprehensive Plan Initial Studies (Future Jobs, Economic Opportunity and
Housing Study and Fiscal Impact of Alternative Growth Scenarios Report);
Comprehensive Plan Existing Conditions Technical Background Report; and
Input and guidance from the Growth and City Form Plan Element Working
Group (PEWG).
3 Challenges, Opportunities and Key Issues
3.1 Introduction and Overview:
The City of San Antonio has many assets that make it a desirable place to live and a
place that is estimated to capture a significant number of new residents and
employees. These assets serve as the basis of future opportunities. However, changes in
demographic trends, land supply, development patterns, and other factors have
generated challenges that the City must address to develop sustainably, to be
economically competitive, and to retain a higher quality of life for its citizens. The City’s
assets, challenges, and opportunities are described below.
3.2 Assets, Challenges and Opportunities:
Assets and Opportunities
The major assets that will impact the future growth of San Antonio are explored in this
section. The underlying assets, opportunities, and challenges that this plan must address
are driven by the forecast for new growth for the city and region. San Antonio, with a
total population of 1.44 million (2014 US Census), is the seventh largest city in the nation.
The City of San Antonio passed Dallas in the early 2000’s to become the second largest
city in Texas. The City of San Antonio and Bexar County experienced strong population
and employment growth over the past decade. These trends are expected to continue
as an additional 1.1 million people and over half a million jobs and households are
forecast by the Alamo Area Metropolitan Planning Organization (AAMPO) to locate in
Bexar County between 2010 and 2040. This amount of growth would almost double the
existing population in Bexar County and the City.
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On the one hand, the forecasted amount of growth represents a lot of opportunity for
San Antonio. The city will have a range of demand for housing types from a growing
diversity of residents. Additionally, the growth will generate a variety of new jobs
needing varying sites and buildings to locate in. Aligning the land use plan for the city
to match market demand and consumer and employer preferences will allow the city
to diversify its housing stock, generate additional economic activity, expand the market
for potential residents and employers, achieve other land use and economic
objectives, and lastly help address issues such as affordable housing, income/economic
segregation, and even health goals and objectives.
The major assets of the city are the main reason why this amount of growth is forecast.
San Antonio is home to primary employment centers and economic engines in the
greater San Antonio-New Braunfels metropolitan area. San Antonio’s core economic
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assets are the major drivers for its four traditional industries (tourism/hospitality, health
care, education, and military). The city also has other major economic assets, both long
standing and emerging, that provide the city with a diversity of opportunities for future
economic growth. The city’s economic assets are explored below.
San Antonio is a major tourist
destination in the U.S. and hosts
more than 31 million visitors
annually that come to shop, play
and/or
conduct
business.
Anchored by its unique history
and culture, San Antonio is home
to the Alamo, River Walk, and
major
attractions
such
as
SeaWorld San Antonio and Six
Flags Fiesta Texas. In addition,
San Antonio has successfully
invested in its cultural and
historical assets as well as newer
developments nearby. These include the Henry B. Gonzalez Convention Center, the
Museum and Mission reach on the River Walk, the Tobin Center for the Performing Arts,
and the Pearl Brewery development. The San Antonio Missions are a National Historical
Park, were recently named a World Heritage Site, and are another major cultural asset
driving tourism activity in the city. Of the 31 million total visitors annually, 24.9 million
were leisure visitors.
San Antonio is also an attractive place to do business. The business friendly and low tax
environment in Texas appeals to many companies considering locating in San Antonio.
Also adding to the appeal are the City’s municipally owned utilities, CPS Energy and
San Antonio Water System. The ability to provide affordable energy and water, and
having utilities with the ability to be innovative in their approach to long-term service
provision is a major draw.
San Antonio’s economy has grown steadily over the past ten to fifteen years and Bexar
County as a whole is forecast to add over a half million jobs by 2040. This economic
growth will drive demand for housing and hopefully opportunity for existing residents to
improve their housing conditions. San Antonio has a polycentric economic geography
with multiple large concentrations of employment throughout the City. Multiple job
concentrations throughout the city can make living near work easier for a lot of
residents. There are also challenges with this polycentric employment pattern in terms of
Growth And City Form Policy Paper
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establishing a coordinated approach to job growth and connecting residents to jobs
through multiple modes of transportation. Continued growth in these centers of
employment and housing will help keep travel distances and commute times lower for
residents of the City and provide potential opportunities for better multimodal
connectivity.
San Antonio has several major locational attributes that are assets to the economy and
make it an attractive place to live. Proximity to the Eagle Ford shale formation, and the
fracking of natural gas that it is has enabled is a major asset to the City. The primary
active area for drilling is along I-37 between San Antonio and Corpus Christi, which has
made San Antonio a major hub for business, services, goods and housing needed to
support the drilling activities in the Eagle Ford. The City’s location near major sea ports in
Houston and Corpus Christi, and major interstates is an important asset as well.
Connectivity to those ports via roadway and rail makes San Antonio a competitive
logistics location facilitating national and international trade. San Antonio’s regional
neighbor, Austin, is experiencing significant growth and is a major attractor of new jobs
and residents. These communities share many of the same attributes and assets, and a
coordinated approach may generate more opportunities for growth in the larger
central Texas region.
The quality of life in San Antonio is a big asset to the community. An important
component to the quality of life is the relatively affordable cost of living in San Antonio.
The cost of living and
average home prices are
both
below
national
averages. Coupled with
strong economic growth
and
relatively
short
average distances to
work and commute times,
San Antonio is appealing
to new residents. Also
adding to quality of life, is
the San Antonio’s strong
cultural
heritage
that
gives it a unique sense of
place, manifested in its
well-known public spaces,
such as the River Walk.
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The city’s historic neighborhoods are another example of how the heritage of the city
impacts housing and neighborhoods. The demographic makeup of the city’s 27 historic
districts is largely a mirror of the city as a whole. The historic districts are also some of the
most desirable neighborhoods in San Antonio. A study commissioned by the City’s
Office of Historic Preservation in early 2015, found that the property values in the historic
districts have increased over the past 15 years more than the city as a whole. The
historic districts have many of the characteristics of neighborhood types that are in
demand nationally, including walkablility (all the historic districts have a higher Walk
Score than the city-wide average), a greater mixture of uses, and even shorter
commute times to work for their residents.
There is additional opportunity for sustainable infill development in the urban core as
well. The Comprehensive Plan Initial Studies found that there are a large number of
vacant and under-utilized parcels within the inner core of the City (inside Loop 410) that
are zoned commercial and industrial. This indicates a discrepancy between zoned uses
and market demand, which suggests that these uses and buildings are out of date and
do not meet current market demand with their current purpose. Allowing for these
commercial- and industrial-zoned areas to redevelop with a wider mix of uses, and
specifically introducing housing, can help revitalize these areas and help improve the
existing neighborhoods around them.
Lastly, San Antonio has a number of large, transformational development projects,
which are important catalyst development sites and have the potential to change the
prevailing direction of growth within San Antonio. Four of these transformational
development sites include Hemisfair, Brooks City Base, Port San Antonio and the Texas
A&M San Antonio Campus and associated development. The development, or
redevelopment, of these sites has the potential to catalyze development in portions of
the city where recent growth has been relatively limited. More significantly, they are
located in areas where an ample supply of developable land capacity exists. The large
size, limited number of owners, and public and political backing for these sites allows for
the opportunity to create model development projects that can serve as a guide for
future growth in the city.
Challenges
Despite the numerous assets described above, the City does lack some key features
and has challenges that impact the future growth and health of the community.
Historically, San Antonio has had no major physical or political constraints to outward
expansion. However, this is no longer the reality for the city. The City boundary in the
north and northeastern parts of San Antonio has effectively reached the edge of Bexar
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County and the boundaries of multiple jurisdictions on the north including Boerne,
Bulverde, Converse, Live Oak, Schertz, and Universal City. The western edge of the City
has begun to enter Medina County. This continued outward expansion has led to
resources being spread across an even larger geographic area and a perception of
disinvestment in the inner portions of the city among some residents.
Changes to annexation law in 1999 made annexation more onerous for the City. As a
result, the City greatly curtailed its annexation efforts from 2000 to 2012. In the absence
of annexation, a large amount of development occurred in the unincorporated portion
of Bexar County. The impacts of this amount of development led Bexar County to
commission a study in 2014 to understand the impacts of urban level development in
unincorporated Bexar County. The study identified that Bexar County is limited, like
other Texas counties, in its authority to fund and provide services to an urban level of
development. The major limitations include the inability to enforce zoning, perform
building inspections, and raise enough revenue through bond issuance to offset the
costs of infrastructure and service costs. Any development within the City’s Extra
Territorial Jurisdiction (ETJ) that occurs in the county is subject to the City’s development
standards, but there are not mechanisms for enforcing this once plans are approved. In
some cases, these developments have generated unforeseen impacts, exacerbated
by the fact that the City has limited control of this development.
Physical and environmental barriers also
reduce the developable land capacity in
the city, especially in its high growth areas in
the northern part of the city and Bexar
County. In the Comprehensive Plan Initial
Studies, impacts on development capacity
from the 100-year floodplain, the Edwards
Aquifer recharge zone, steep slopes, and
environmentally
critical
habitats
were
estimated to create a 27% reduction in
development capacity. The northern portion of the city and Bexar County, specifically
north of Loop 1604, is most impacted by these physical barriers. Development capacity
is reduced in the northwestern portion of the city and county because of topography
and the Edwards Aquifer Recharge zone. The topography makes providing sewer
service costly and difficult in some areas. As well, in 2011, at the direction of the SAWS
Board, a service area expansion application for a portion of northwest Bexar County
was withdrawn. SAWS staff reported that stakeholders expressed concerns surrounding
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the environment (specifically the impact to the Edwards Aquifer) and expressed their
views to the Public Utilities Commission (PUC). Prior to a PUC decision, SAWS formally
withdrew its requested expansion to its Certificates of Convenience and Necessity
(CCN) for water and sewer service. Based on the concerns expressed by local
stakeholders, the SAWS board modified the application and contracted the boundary.
Provision of Utilities
The City’s growth plans and policies had been out of line with plans of the city’s major
utility providers until recently. SAWS adopted a Growth Strategy in April of 2010.
Generally, the agency finds that growing its infrastructure system generates benefits
and at the same time eliminates potential problems. SAWS seeks to proactivity serve
areas (either through utility service agreements or service area expansions), as it
prevents the proliferation of agencies, some of which may not have the expertise and
may not be able to effectively run their plants. If SAWS denies service, a developer can
find an alternative service provider and apply for its own service area to the PUC and
construct a package plant. In the event SAWS chooses not to serve, the service area
request typically leads to negotiations where the new provider has to build to SAWS
specifications in the event SAWS must take over the operations at a future date. SAWS
has played this role multiple times and has legitimate concerns about the lack of
expertise and/or critical mass of new agencies to effectively operate smaller systems.
However, the extension outward by SAWS to prevent competitive and/or substandard
utility providers may conflict with the City’s growth plans and lead to incongruent
growth policies despite the stated goal of a coordinated approach.
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Housing Development
Over the past decade, San Antonio has been losing its competitive market position for
capturing single family housing development within the metro area as developers and
home buyers look outside the City’s boundaries for more attractive opportunities. San
Antonio has been capturing a decreasing share of single family home development
within the Metropolitan Statistical Area (MSA) and now captures less than half of such
new development. Developers have begun working in unincorporated parts of Bexar
County due to several reasons including favorable public financing structures provided
by the County. This has led to a large amount of development outside the City’s
boundaries and control; however, the development still relies on the support of City
services and infrastructure. Single family home buyers over the past decade have
found it cheaper and more attractive to buy homes in the surrounding suburbs, which
have been facilitated by infrastructure improvements that allow for easy access in and
out of the city’s periphery.
Market trends, combined with the land capacity analysis in the Comprehensive Plan
Initial Studies, indicate that growth patterns are changing. Housing development in San
Antonio since 2000 has occurred primarily in the north and western portions of the
County. The northern portion of the city has captured the majority of growth in the past
10 to 15 years. This will change as the areas are nearing build-out given the lack of
available land, topographic constraints, traffic congestion, and corresponding
challenges for utility service. Residential growth is projected to occur more to the west,
and to some degree, to the south. Depending on the city’s ability to create policies
and infrastructure (utilities, schools, services, etc.) changes that attract growth,
development momentum may shift to locations within the city limits or may continue
expanding into other counties.
The Comprehensive Plan Initial Studies found a lack of residentially zoned land to
accommodate the forecasted demand for housing in several portions of the city. There
is a lack of land supply to capture housing development, particularly within the north
part of the city if development continues under the same density and development
patterns. Increasing the density of neighborhoods and the average density of single
family development will help reduce some of the demand for land. Additionally, there is
an oversupply of land within underutilized commercial and industrial zoned parcels.
Areas with large concentrations of vacant and underutilized commercial and industrial
parcels can be repositioned as residentially focused mixed use neighborhoods, which
will increase the supply of residential land in these inner subareas.
An analysis of the fiscal impact of new development was completed as part of the
Comprehensive Plan Initial Studies. This analysis had two main findings regarding new
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development. First, infill development was found to have a lower fiscal impact than
greenfield development. Second, the density of a development has a major impact on
its fiscal impact. Five development programs were tested in the Initial Studies to
compare the fiscal impact of existing development patterns with alternative
approaches. The denser programs tested had the greatest net fiscal impact on the
City. Bexar County also recently analyzed the fiscal impact of development. The
County’s study found Bexar County is not equipped to provide urban services due to
limitations in its revenue generation and service provision tools provided by the State,
which means development in these areas cannot be served with an adequate level of
urban services, ultimately creating a burden for the city.
Analysis of housing preference surveys and existing housing conditions in San Antonio
completed in the Comprehensive Plan Initial Studies indicated there is unmet demand
for walkable neighborhoods based on existing conditions and consumer preferences.
San Antonio lacks walkable neighborhoods as only 14% of neighborhoods in the city
have a Walk Score that indicates a somewhat or very walkable location. Despite
limited new single family development projects built with a more walkable design, there
are indications locally that there is demand for this type of development, as indicated
by recent inner city development and by the strength of the city’s historic
neighborhoods which, on average, are more walkable the rest of San Antonio.
Dispersed Employment
Employment in San Antonio has a polycentric geographic pattern. The composition of
the economy and the presence of multiple major employment nodes (i.e. downtown,
Medical District, military bases, etc.), have dispersed employment opportunities and
major economic assets throughout the city. Consequently, it is often difficult to discern
major concentrations of employment within the city. This reflects the dispersed nature of
the major economic drivers of the city’s economy (military, healthcare, education, and
tourism). Another important contributing factor to this dispersed employment pattern is
the lack of adequate land use controls or incentives, and a lack of appropriate master
plans to guide/attract employment growth. The scattered economic assets and lack of
coordinated growth plans around these assets has made it hard for the City to leverage
these assets to their potential and to create spin-off economic activities as the result of
clustered businesses in similar industries.
Growth And City Form Policy Paper
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Growth and City Form Policy Paper
18
The analysis, within Comprehensive Plan Initial Studies, on the density of jobs within
Bexar County, however, found that jobs within the city have somewhat organically
concentrated into centers/nodes. The concentrations have appeared largely along
major transportation routes. Thirteen employment centers were identified within the city,
nine existing centers and four emerging. These 13 regional centers (see map on page
18) represent an opportunity to align economic development efforts with land use
planning and infrastructure investment to develop strategic growth plans that focus
economic activity within these centers. The centers have the potential to offer a wide
variety of opportunities for employment-oriented uses, sites, infrastructure, and
amenities. As well, some of the centers offer the potential to create the type of vibrant,
mixed-use places that allow for live-work-play environments that are attracting
development and businesses nationally, but that are lacking in San Antonio.
3.3 Key Issues
Several key issues emerged from previous reports and efforts, as well as the research
and outreach completed during the SA Tomorrow process. The assets, opportunities
and challenges described above illuminate several of these key issues. The issues
identified are posed as questions below to help form the policies included in this paper.











How will San Antonio accommodate the half a million new jobs and households
forecast to locate in Bexar County by 2040?
How can San Antonio utilize annexation strategically?
Where in the City should higher intensity growth be directed and encouraged?
What forms of development will help the City achieve its stated Goals in other
Plan elements?
How can growth be managed in a way that respects and protects the City’s
natural resources, historical features, and cultural assets?
Which direction can and should growth go within the city given the lack of land
in traditionally high growth areas (north and west)?
How can the City shift development momentum to areas that traditionally have
had limited demand for new development?
How should the provision of services from SAWS, CPS, VIA and others be
connected to City’s growth plans?
Do the City and SAWS have enough water to serve future growth? Should the
City and SAWS direct growth through water provision policies and decisions?
Should San Antonio grow (more so) into counties other than Bexar?
How should San Antonio address development in unincorporated Bexar
County?
Growth and City Form Policy Paper
19

What is the City’s role in providing infrastructure for new development in
greenfield and annexation areas?
4 Key Strategies and Lessons Learned
The twelve key issues identified above have guided the development of the Growth
and City Form goals and policies during working group deliberations. This section
examines two approaches to addressing these issues that are particularly interesting
and relevant when considering alternative ways in which San Antonio should develop
over the next 25 years:

Determining where to direct higher intensity growth while also managing that
growth to protect critical natural and manmade resources; and

Encouraging forms of development that will help the City achieve its stated
goals in other Plan elements.
This section further examines the implications of these two strategies and explores how
they can be used to achieve regional economic and environmental goals while
creating livable communities in which people can live, work and play.
4.1 Directing growth while protecting critical natural resources
San Antonio has a relatively fixed area available for future population and employment
growth. How this growth is accommodated will over the coming years and decades
impact the City’s overall quality of life and livability. This includes the need to ensure
future development does not occur in areas that could negatively impact vital natural
resources such as the Edwards Aquifer. The City of Austin has been dealing with a similar
set of challenges and its efforts to manage and direct its growth holds lessons for San
Antonio.
Austin, Texas: Smart Growth and Urban Containment Policies
The City of Austin and the greater metropolitan area (Austin-Round Rock region) has
been one of the fastest growing regions in the country. From the 1950s to early 1970s,
Austin grew more than 35% in each decade. More recently, between 2000 and 2010,
Austin’s population grew by 20%; making it the 14th most populous city in the US and by
2011 the city reached a total population of 812,025. About two-thirds of this growth is
attributable to natural expansion (more births than deaths) and new residents moving
Growth and City Form Policy Paper
20
into Austin, while about one-third of the new population was added through
annexation.
Despite this growth, Austin’s share of the Austin-Round Rock region’s population has
been declining. In 1960, 65% of the region’s population lived within the Austin city limits.
By 2000, this had dropped to 52.5%, and by 2010 it dropped to 46%. In addition,
although there has been a modest trend of infill development and redevelopment in
established areas of Austin, the pace of urban core development lags far behind new
development in suburban areas and beyond. In 2010, Austin was denser (2,653 persons
per square mile) than in 2000 (2,477 persons per square mile) but it remains less dense
than most major cities in Texas, including San Antonio (2,880 persons per square mile),
as well as peer cities across the country.
Natural resources have also had
a huge impact on land use and
growth management policies.
The Edwards Aquifer, one of the
most important and sensitive
aquifers in Texas, feeds a number
of springs in Austin. Portions of its
500-square mile recharge zone
extend on a north-south axis
through the western part of the
city. Austin has a long history of
regulations to protect its water
supply and nearly 37% of the
city’s area is included in one of
the
three
drinking
water
protection zones. Although 34
percent of Austin’s land area is
classified as “undeveloped,”
much of it has environmental
constraints. At the same time
Barton Springs is the main discharge point for water that enters
more than 50,000 acres of
the Barton Spring segment of the Edwards Aquifer (Source:
undeveloped land with no
austintexas.gov)
environmental constraints are
located in suburban watersheds
in the eastern part of the city.
Growth and City Form Policy Paper
21
Population projections show that Austin will almost double in population in thirty years.
This will place heavy demands on infrastructure, resources, and services. Some of this
growth will occur through annexation of unincorporated areas, but much of the growth
will need to be accommodated through development within the city. However,
environmental constraints will add more pressure on developing land outside the city
limits.
Over the years Austin has launched a series of planning initiatives to manage and
direct growth. The Austin Tomorrow Comprehensive Plan (ATCP) was adopted in 1979
when the City had a population of less than 350,000. A preferred growth scenario or
concept emerged after using an extensive overlay system for identifying and mapping
environmentally sensitive lands and lands unsuitable for development. The preferred
scenario established five “growth areas,” three areas where new development and
redevelopment was desired and two areas where they were not.
Beginning in 1997, the city
began to actively implement
policies to foster a more
compact and efficient urban
form. The Smart Growth Initiative
(1999)
was
adopted
to
modernize Austin’s long-range
plan (Austin Tomorrow) for
growth, managing and directing
growth that minimized damage
to the environment and helped
build a more livable city. The
tenets of the City’s Smart Growth
initiative were consistent with the
general
policies
of
Austin
Tomorrow, discouraging growth
in the west by creating the
“Drinking Water Protection Zone”
to protect water supply and
growing city boundaries in the
east by creating the “Desired
Development Zone”, taking into
Smart Growth Map (Source: City of Austin, 2003)
Growth and City Form Policy Paper
22
account geographical and utility constraints. Most of the major north-south and eastwest thoroughfares were designed as Smart Growth Corridors. The Smart Growth Map
depicts where the City wants to direct future growth—in the Desired Development Zone
(DDZ), and where growth should be discouraged due to environmental concerns—in
the Drinking Water Protection Zone (DWPZ).
The DDZ and the DWPZ were included in a September 1997 ordinance which linked
planning to environmental protection. To encourage growth within the DDZ, the City
Council approved development and utility fee reductions, differentiated utility
reimbursements and a Smart Growth Matrix. Together, the fee structure and
reimbursement policy incentivize development in the DDZ and create a financial
penalty for developing in the DWPZ.
Between 1997 and 2012, neighborhood plans served as Austin’s primary planning tool
and functioned as an alternative to a citywide comprehensive plan.1 City officials also
set about creating a Traditional Neighborhood Development (TND) ordinance and a
complex set of infill and Redevelopment Amendments to the city’s building code. The
TND was created to establish denser development surrounding commuter rail stops,
improve connectivity between the surrounding community and the TOD district, and
establish housing affordability goals for new development. The number of TOD districts
would increase as new light rail lines got built. The City’s neighborhood planning
process complemented the broader concept of Smart Growth and served to update
the comprehensive plan.
Austin has accomplished multiple goals using the Smart Growth Initiative. Not only did
the initiative establish the Drinking Water Protection Zone (DWPZ) and the Desired
Development Zone (DDZ), it also established policies to encourage development in the
DDZ through financial incentives. After a comprehensive mapping project showed that
new housing construction was negatively affecting the city's all-important drinking
water source, the Edwards Aquifer, the city decided to direct its public transportation
and park investments to East Austin in an attempt to attract developers to concentrate
growth on the less sensitive east side of town. East Austin is not only outside the drinking
water protection zone but also is an area historically underserved by parks.2
As a result of the TND ordinance, at sites across town, older developments are being
torn down to make way for new mixed-use developments that are changing not only
the character of the city but the way people live, work, shop and recreate, with ripple
1
Walters, M. (2013). Neighborhood Plans and the Comprehensive Plan: Austin’s Experience. www.planning.org.
Retrieved 10 November 2015, from https://www.planning.org/thecommissioner/pdf/13sum.pdf
2 https://www.planning.org/cityparks/briefingpapers/smartgrowth.htm
Growth and City Form Policy Paper
23
effects throughout the local economy. In many cases, the new, denser development is
replacing sites that housed decades-old apartments, as is happening along East
Riverside, or industrial sites, like the prime waterfront land downtown where the Seaholm
Power Plant and Green Water Treatment Plant once operated that will be transformed
with luxury apartments, offices, shops and restaurants.
Seaholm Power Plant Redevelopment, Austin, Texas
(Source: en.wikipedia.org/wiki/Seaholm_Power_Plant)
Lessons for San Antonio
The City of Austin has established Desired Development Zones and ‘Smart Growth’
Incentive Programs which act as both Urban Service Areas and Urban Growth
Boundaries. They map out where the city wants development and provide incentives
through infrastructure and tax breaks to entice development into these desired
development zones and away from the open space they want to preserve.
The Edwards Aquifer west of Austin now has thousands of acres of protected green
space, paid for by bonds authorized in the first flush of Smart Growth enthusiasm. Austin
has zoning and development code that integrates urban design issues. The City also
has a permitting process in which neighborhoods have real representation. While
encouraging infill and development (smart growth incentives, DDZ) in the eastern
portions of the city, the city has also taken efforts to discourage development in
sensitive areas to the west (DWPZ and buffer zones). The city has also imposed
Growth and City Form Policy Paper
24
significant restrictions under its watershed protection ordinance for a number of years.
These incentives, financing and regulatory tools can be applied to San Antonio as well
to protect lands in and around the Edwards Aquifer.
4.2 Encouraging forms of development that will help the City achieve its stated goals in
other Plan elements
Over the past decade developers and home buyers have been looking outside San
Antonio’s boundaries for more attractive opportunities, leading to a large amount of
development in unincorporated areas of Bexar County outside the City’s boundaries
and control. Given growth projections that anticipate a near doubling of the existing
population in Bexar County and San Antonio between 2010 and 2040, San Antonio
needs to create policies and infrastructure that can shift growth to areas within its city
limits. Such a shift in the region’s urban growth pattern will encourage the development
of more compact, mixed use walkable communities that can bring about multiple
environmental, economic, mobility and livability benefits. Over the past few decades,
the metropolitan area that includes the City of Portland, Oregon is notable for its
success in managing its growth in order to achieve multiple regional goals.
Portland, Oregon: Development Strategies to Achieve Multiple Benefits
Metro areas with more compact, connected neighborhoods are associated with better
overall economic, health and safety outcomes—a better quality of life for everyone in
that community.3 As communities recognize the health, safety and economic benefits
of better development strategies, many decision makers are reexamining their
traditional zoning, economic development incentives, transportation decisions and
other policies that have helped to create sprawling development patterns. Instead,
they are choosing to create more connections, transportation choices and walkable
neighborhoods in their communities. The Portland metro region in Oregon is perhaps the
most frequently cited example of an American metropolis working to reduce its
dependence on the automobile. It is the center of a three-county metropolitan area
with roughly 1.3 million residents. Portland’s commitment to planned growth and antisprawl sentiment pre-dates the public outcry now arising in many U.S. cities. Its
approach rests on the concept of linking public transportation and land use. In contrast
to most American cities, Portland has a very empowered and effective regional
government (Metro) that coordinates urban growth of cities within the Portland metro.
Formed in 1979, Portland Metro was given a home rule charter in 1990 that provided for
3
"Measuring the impact of Sprawl." Government Finance Review June 2014: 5. Academic OneFile. Web. 19 Oct. 2015.
Growth and City Form Policy Paper
25
a directly elected regional government. The Metro region encompasses 24 cities and
parts of 3 counties, comprising 232,000 acres.
Some of the public policies in Portland that have contributed to urban growth
management include the following:

Urban Growth Boundary and Metro’s 2040 Growth Plan. For the past 30 years,
Portland has protected fertile farmland and open space by limiting the
development of sprawling suburbs and exurbs through strict controls over the
location of growth. Within the Portland metro area, each city in Oregon is
required to maintain an urban growth boundary (UGB) beyond which
development is discouraged, limited or prohibited. Portland Metro, the regional
planning authority uses the Metro 2040 Growth Concept which is a long-range
plan to set a regional framework for how growth will be concentrated in the next
20 years. The plan is based on goals for making efficient use of land, protecting
natural areas and farm land, and promoting a multi-modal transportation
system. In Portland, the 2040 Growth Concept calls for concentrating residential
and commercial development in and around mixed-use areas and in light rail
station communities called “Centers” that include the Central City, the Gateway
Regional Center, six town centers (Hollywood, St. Johns, Lents, Hillsdale, West
Portland and Raleigh Hills), and along “Corridors” such as main streets and along
select neighborhood corridors.

Parking Management: Portland
has devised local parking
policies around transit. While
many
local
governments
maintain
high
parking
requirements even in transitrich areas, new developments
in Portland near frequent
transit
have
no
parking
requirements. This gives the
option of determining parking
ratios to developers and the
housing market rather than
local governments. Since an
average parking space adds
$40,000 to the cost of a
housing unit, allowing for
unbundled parking with lower ratios has a huge effect on housing affordability
near transit. These parking policies go hand-in-hand with the 2040 Growth
Concept that calls for concentrating high densities in and around light rail
stations and mixed-use areas.
Growth and City Form Policy Paper
26

Transportation Choices: Over the past 15 years, Portland has had many New
Starts-funded transit projects, having built five major MAX light rail extensions
totaling nearly 38 miles. Portland recently added another light rail extension that
connects it to the City of Milwaukie. Portland’s streetcar system doubles up as a
tool of place making apart from being a mode of transportation. Since opening
in 2001, 10,000 housing units and $4 billion in economic development have
occurred within three blocks of the four-mile streetcar line, and new districts
have emerged such as the Pearl District, South Waterfront and the Central
Eastside.
Lessons for San Antonio
Portland has demonstrated that more compact forms of development which allow for
higher population and employment concentrations with greater densities, more
efficient land use and less sprawl can yield significant fiscal, mobility, environmental,
and livability benefits. In Portland this was achieved through an array of public policies
working in concert with each other, the most notable being the urban growth
boundary which limited development outside the area defined by this legal boundary.
What helped make this possible was the establishment of Portland Metro (Metro), the
first and only directly-elected regional government in the United States. It encompasses
not only the City of Portland but also 23 other cities and parts of 3 counties. Metro
coordinates growth of these cities by ensuring the plans of these local jurisdictions are
consistent with the Metro 2040 Growth Concept, the long range growth plan for the
region.
5 Recommended Goals and Policies
5.1 Growth and City Form (GCF) Goals
Eight goals were developed to fulfill the City’s vision and to address the key issues
identified for the Growth and City Form element.
GCF Goal 1:
Higher density uses are focused within the City’s 13 regional centers
and along its arterial and transit corridors.
GCF Goal 2:
Priority growth areas attract jobs and residents.
GCF Goal 3:
Strategic annexation benefits existing and future City residents and
does not burden the City fiscally.
Growth and City Form Policy Paper
27
GCF Goal 4:
Sustainable infill and mixed-use development provide walkable and
bikeable destinations for all residents.
GCF Goal 5:
Growth and city form support improved livability in existing and future
neighborhoods.
GCF Goal 6:
Growth and city form support community health and wellness.
GCF Goal 7:
Development practices avoid, minimize or mitigate negative impacts
on the city’s natural resources, water supply, water quality, surface
waterways, and air quality.
GCF Goal 8:
Students throughout San Antonio have enhanced educational access
and perform at a high level. (See also PFCS Goal 4)
5.2 Growth and City Form (GCF) Policies
Priority Growth Areas
GCF P1:
Incentivize the development of housing and employment uses in the
city’s priority growth areas.
GCF P2:
Identify and support catalyst projects which include a mix of housing
types for a range of income levels and which attract additional
employment.
GCF P3:
Invest in neighborhood amenities and infrastructure (including green
infrastructure) that will attract new residents to priority growth areas.
GCF P4:
Create subarea/corridor plans for the City's regional centers, major
arterials, and transit corridors to ensure maximum coordination of land
use, transportation and other infrastructure in support of higher density
development.
GCF P5:
Invest in needed amenities and infrastructure that will facilitate higher
density development in the city’s priority growth areas.
GCF P6:
Align land uses and infrastructure improvements in regional centers
with employment uses and jobs best suited for each center’s unique
assets.
Growth and City Form Policy Paper
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GCF P7:
Ensure employment centers provide a variety of land uses and
infrastructure that will allow the city to remain economically
competitive.
Infill and Revitalization
GCF P8:
Continue to focus on the revitalization of neighborhoods adjacent to
downtown and extend these efforts to regional centers and transit
corridors.
GCF P9:
Allow higher density and mixed uses in portions of, or adjacent to,
single-family residential areas to encourage shopping, services, and
entertainment amenities in closer proximity to housing.
GCF P10:
Develop a plan to preserve and maintain affordable housing within
revitalizing neighborhoods and along transit corridors.
GCF P11:
Continue and bolster incentive programs for infill development in
priority growth areas.
GCF P12:
Develop programs to encourage and incentivize adaptive reuse.
GCF P13:
Evaluate commercial and industrial land use and zoning designations
in the core of the City, regional centers, and primary transit corridors to
determine areas that could be converted to residential or mixed-use.
Annexation
GCF P14:
Work with AACOG, AAMPO, and other regional partners to determine
a consistent approach for forecasting growth in the region and
develop a strategic, proactive approach to annexation that is
consistent with the adopted growth forecast.
GCF P15:
Ensure the City’s annexation policy supports desired city form.
GCF P16:
Ensure that newly annexed residents of the city receive the same level
of service as current residents.
GCF P17:
Ensure that annexation decisions do not create an undue fiscal
burden on the City or utilities providers, SAWS and CPS.
GCF P18:
Ensure that the City's growth and annexation plan provides guidance
for growth plans and policy decisions made by the major utility
providers, SAWS and CPS.
Growth and City Form Policy Paper
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Transit
GCF P19:
Work with VIA Metropolitan Transit to develop a long-term transit plan
that increases transit connectivity to employment centers.
GCF P20:
Work with VIA Metropolitan Transit to develop a long-term transit plan
that facilitates transit-supportive development.
Natural Resources and Environmental Sustainability
GCF P21:
Encourage development types and designs that promote and support
water conservation practices.
GCF P22:
Implement stormwater infrastructure management best practices that
balance well-developed and well-maintained regional and sitespecific stormwater infrastructure (i.e., gray and green infrastructure).
(See also NRES P17 and PFCS P13)
GCF P23:
Require developments in or near the recharge and contributing zones
and in areas identified by the watershed master plans of the Bexar
Regional Watershed Management Consortium to use low impact
development techniques, to meet minimum standards for pervious
area and to develop natural resources mitigation plans.
GCF P24:
Explore incentive and enforcement programs for Low Impact
Development (LID).
GCF P25:
Discourage land intensive development patterns in the Edwards
Aquifer recharge and contributing zones and along preservation
reaches of rivers and creeks. (See also CHW P34 and NRES P11)
GCF P26:
Purchase undeveloped land within the Edwards Aquifer recharge and
contributing zones and along river and creek corridors for public open
space.
GCF P27:
Incentivize development that is consistent with recommendations
within the watershed master plans of the Bexar Regional Watershed
Management Consortium.
GCF P28:
Develop regulations, incentives and other tools to facilitate
development types and designs that promote and support water
conservation practices.
Growth and City Form Policy Paper
30
GCF P29:
Develop regulations, incentives and other tools to facilitate
development types and designs that protect natural resources, water
quality, surface waterways and air quality.
GCF P30:
Promote development that leverages and protects the public’s
investment in major green infrastructure and natural resources projects
(such as the San Antonio River Improvements Project and other creek
and trail restoration projects). (See also PFCS P9)
Schools and Education
GCF P31:
Support and invest in existing schools and their neighborhoods.
GCF P32:
Promote innovative educational opportunities within priority growth
areas of the city to drive market demand for housing.
GCF P33:
Help provide land, facilities, and/or entitlements that can be used to
establish schools that attract a broader spectrum of families with
children.
GCF P34:
Collaborate with and provide support to underperforming
independent school districts to enhance access and improve
performance.
GCF P35:
Increase funding and support for early childhood education programs
in underperforming school districts.
6 Next Steps
It is important to note that the policy papers are neither exhaustive nor all-inclusive
products. Instead, they are intended to help facilitate conversation around key issues
and to inform long-term Comprehensive Plan policy options. The policy papers
summarize key background information, but do not attempt to repeat previous work.
Instead, they are concise and targeted to support their overall purpose, which is to
augment productive deliberation about how best to achieve a bold, strategic vision for
San Antonio’s future. As such, much of the content will feed directly into the
Comprehensive Plan document.
The Goals and Policies presented in the Policy Papers will form the basis of the Goals
and Policies for the Comprehensive Plan elements. However, as the Plan is drafted, the
Goals and Policies may continue to evolve and be refined based on public input,
Growth and City Form Policy Paper
31
feedback from community leaders, Neighborhood Associations, and focus groups, as
well as discussions with the Plan Element Working Groups. In particular, the final phase
of the Comprehensive Plan process, focusing on stitching together the goals and
policies with regional centers, neighborhood and district types, may inform further
revisions and refinements to the Goals and Policies.
Growth and City Form Policy Paper
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