What shapes a site plan in metro San Antonio
In metro San Antonio the Edwards Aquifer, not a use table, sets the hardest numbers on a north-side site, and the counties around the city regulate land through plats and infrastructure. Five conditions follow, and each one changes how a preliminary site plan is drawn here.
- An aquifer overlay sits on every base zone. North of the city, the Edwards Recharge Zone District (ERZD) applies to all base zones; UDC Sec. 35-521 appends it to the zoning designation as a suffix, so a multifamily parcel reads MF-33(ERZD), and rezoning procedures apply to it [1]. Inside the district, Sec. 35-332 restricts uses that produce or store hazardous materials [7].
- Impervious cover is capped by category. The San Antonio Water System's aquifer ordinance holds land in the ETJ recharge zone under Category 3 (Ordinance 81491) to 15% impervious cover whether the use is single-family, multifamily or commercial, and its Category 2 example allows 30% for single-family, 50% for multifamily and 65% for commercial [2]. Under City Code Chapter 34, Article VI, Division 6, floodplain buffer zones take no impervious cover at all and a drainage area buffer zone takes no more than 10% [2, 8].
- TCEQ reviews the same ground. The Edwards Aquifer rules of 30 TAC Chapter 213 apply in Bexar, Comal and Medina counties among others [9], and regulated activities need TCEQ approval before soil is disturbed [10]. Once an application is administratively complete, TCEQ's technical review runs 90 days under 30 TAC 213.4(e); that is the agency's plan review period, not a city site plan approval [11].
- Growth is steady. The metro added 38,402 residents from 2024 to 2025, ninth among US metros, and grew from 2,558,389 in 2020 to 2,813,140 in 2025, a gain of 254,751 or about 10.0% [3].
- The counties around the city do not zone. Bandera County's regulations "govern the unincorporated areas of Bandera County and hold no force inside corporate city limits except where there is an interlocal agreement" (Regs. 1.3.4) [6], and Wilson County treats lodging developments with RV parks under Chapter 232 infrastructure rules [12].
Jurisdiction map: who governs where
The first line of a site data table here names the jurisdiction and whether the parcel lies over the recharge or contributing zone.
| Jurisdiction | Governs | What a developer needs to know |
|---|---|---|
| City of San Antonio | Land inside the city; SAWS aquifer categories reach the ETJ recharge zone | UDC Chapter 35; the Zoning Commission recommends and City Council decides zoning [13, 2] |
| Bexar County | Land outside the city limits | A 30 TAC 213 county for TCEQ's Edwards rules [9] |
| Comal County | North-east of the city, toward New Braunfels | A 30 TAC 213 county; county permits for on-site sewage, floodplain development and driveways in the public right-of-way [9, 14] |
| Bandera County | The Hill Country north-west of the city | Unincorporated land under the county's Subdivision and Land Development Regulations; ETJ applicants "will be subject to County regulation" (Regs. 1.3.5) [6] |
| Wilson County | South-east of the city | Infrastructure requirements for lodging and RV park developments [12] |
| City of Boerne | I-10 north-west, in Kendall County | City zoning, development agreements and a Design Review Committee, as its Buc-ee's record shows [15] |
Rules for New Braunfels, Schertz, Seguin and Guadalupe County are confirmed with each jurisdiction before a layout is fixed. The Houston, Austin and Dallas-Fort Worth pages cover the other Texas metros, and site plans in Texas sets out the statewide rules.
Site plan process: City of San Antonio
Zoning comes first in the city: Development Services verifies the zoning, the Zoning Commission recommends and City Council decides a rezoning [13]. Over the recharge zone the aquifer documents and TCEQ's plan run alongside.
| Step | Rule | Source |
|---|---|---|
| Zoning verification or rezoning | Development Services Zoning; Zoning Commission recommendation; City Council decision | [13] |
| ERZD documentation | An aquifer protection site development plan under UDC Sec. 35-B105 showing scale, north point, floodplain preservation areas, recharge features, the erosion control plan and the percentage of impervious cover | [16] |
| TCEQ Edwards plan | Approval before soil disturbance; technical review of 90 days once administratively complete (30 TAC 213.4(e)) | [10, 11] |
| Existing building meeting | On request, the Building Official meets the applicant before a permit application to set how the existing building code applies to a change of occupancy (City Code Sec. 10-5(c)) | [17] |
| Building code | The 2024 IBC and IEBC, effective May 1, 2025, under Ordinance 2025-01-30-0075 | [17, 18] |
| Historic review | Historic and Design Review Commission (HDRC) for districts and landmarks; meetings on the first and third Wednesdays; the OHP page puts a Friday application deadline 18 calendar days before the Wednesday decision | [5] |
The rezoning record shows how office land moves toward commercial use. Case Z-2023-10700340 sought C-2 zoning for 9002 Wurzbach Rd, then zoned O-2, and Z-2023-10700307 sought the same change for 8930 Wurzbach Rd, amended to C-2NA, a nonalcoholic sales suffix; staff recommended approval of both, the Zoning Commission heard them on 12/19/2023, and both were on City Council's zoning agenda of 1/25/2024 [19, 20]. Case Z-2024-10700146, for 1818 N Colorado St from O-1 to NC, was on a 2024 Zoning Commission agenda with a staff recommendation of approval [21]. Zoning Commission agenda items list a site plan with the staff report [20, 21]. The restaurant conversion model project in San Antonio follows this path for an office or retail suite, and commercial interiors and conversions covers the interior side.
Site plan process: Bandera, Comal and Wilson counties
Bandera County. "Submittal, review and consideration of the Preliminary Plan, Preliminary Plat and Final Plat shall be consecutive, not concurrent, and shall be considered by Commissioners Court during separate meetings" (Regs. 3.1.4) [6]. The State "has declared Bandera County to be a Priority Groundwater Management Area" (Regs. 1.1.1(l)), so the plat carries a groundwater availability certification sealed by a PE or P.G., based on an aquifer test of at least 24 hours, and the county "relies on the comments and recommendations of BCRAGD on water availability" before final approval (Regs. 4.2.5) [6]. Construction starts within 90 days and finishes within 12 months of Final Plat approval, under a bond based on the engineer's cost estimate [6]. The RV resort model project in Bandera County takes a Hill Country resort through these stages, and RV park approval in Texas counties compares other county regimes.
Comal County. The county's permits cover on-site sewage facilities, floodplain development and driveways in the public right-of-way, under a Flood Damage Prevention Order [14], and its OSSF page requires engineered planning materials for "Any on-site sewage system serving ... recreational vehicle parks" [22].
Wilson County. Its infrastructure requirements treat lodging developments with RV parks under Chapter 232, and set 10 ft between units [12].
Asset rules in metro San Antonio
| Asset | Rule that applies in metro San Antonio | Source |
|---|---|---|
| Restaurants and conversions, City of San Antonio | Permitted in NC (building size limited to 3,000 SF), C-1, C-2 and C-3; the office districts O-1 and O-2 need a rezoning | [4] |
| Alcohol service, City of San Antonio | "The sale of alcohol for on-premise consumption is allowed at restaurants in all permitted base zoning districts, except those including an 'R' or 'NA' designation"; City Code Sec. 4-6 bars sales within 300 ft of a church, school or hospital, measured under Alcoholic Beverage Code 109.33(b) | [4, 23] |
| Parking, City of San Antonio | IDZ infill zoning waives or reduces minimums; the D Downtown district is exempt; the director may waive up to 50 percent (Sec. 35-526(b)(6)); bicycle parking is 10 percent of minimum vehicle spaces, capped at 24, and 25 percent in D and IDZ (Sec. 35-526(b)(8)) | [24, 25] |
| Sidewalk cafes, downtown | An annual permit at $250, $500 or $750 by size, with at least 6 ft left clear for pedestrians | [26] |
| Multifamily, City of San Antonio | ERZD suffix on the base zone; 15% impervious cover under Category 3 in the ETJ recharge zone; 50% in the Category 2 example | [1, 2] |
| Gas stations and fuel tanks | A SAWS fee on underground storage tanks in the recharge and transition zones (UDC Sec. 35-521); hazardous materials uses restricted in the ERZD (Sec. 35-332) | [1, 7] |
| Travel centers, City of Boerne | Buc-ee's conditions: fueling moved away from Menger Springs, expanded buffers and berms, "Dark Sky-compliant lighting with shielded fixtures," and no opening until traffic mitigation is built | [15] |
| RV parks, Wilson County | Chapter 232 infrastructure rules; 10 ft between units | [12] |
| RV parks, Comal County | Engineered planning materials for any OSSF serving an RV park | [22] |
City Code Sec. 4-6 and UDC Sec. 35-526 are read on a secondary mirror of the code and are paraphrased here. The Board of Adjustment may also adjust minimum or maximum parking on a showing of hardship, and the adjustment applies only to the use in the original certificate of occupancy (Sec. 35-526(b)(7)) [25]. In December 2024 City Council approved reduced or removed parking minimums for the Green Line rapid bus corridor, KSAT reported [27]. State rules for these assets are on gas station site plans in Texas and RV park site plans in Texas; layouts are on the truck stop, multifamily and RV park hubs.
Growth corridors and proof points
The metro reached 2,813,140 residents in 2025 [3]. Housing permits slowed: the metro authorized 14,857 units in 2024 against 16,485, and the City of San Antonio 6,258 against 9,159 [28].
On I-10 north-west of the city, Boerne's Buc-ee's record shows how a large travel center moves through a city. The development agreement was approved on August 9, 2016 (Resolution 2016-R72); a 100 ft sign variance was denied on October 24, 2017; the B-2 rezoning passed the Planning and Zoning Commission unanimously on May 4, 2020 and City Council unanimously on June 23, 2020; the Design Review Committee approved unanimously in December 2021; and construction began in 2025 [15]. The city's briefing records a $40 million private investment announced in August 2016 [15]. The core preliminary plat covered 29.22 acres for a travel center of at least 50,000 SF, planned at 53,471 SF, with at least 90 fueling positions and 18-wheeler fueling prohibited except deliveries [15, 29]. The city said the project is "vested under 2019 city regulations, based on the date of the travel center's preliminary plat application," MySA reported [30].
Inside the city, historic review answers neighbor objections with conditions rather than denials. HDRC minutes of Sept 4, 2024 carry the standard stipulation "That all mechanical equipment be screened from view from the right of way," passed 8 ayes, 0 nays, 3 absent [31]. For Rosario's at 722 S. St. Mary's St., the San Antonio Report reported that the HDRC approved the plan over a neighbor's objection, with a greater setback for fencing and final landscaping and mural designs as conditions [32].
In Comal County, wastewater permits draw contested hearings over the aquifer. Gram Vikas Partners sought a 0.20 MGD discharge to Mesquite Creek under permit WQ0015990001, drawing hearing requests by GEAA and TRPA over water quality and the Edwards Aquifer [33], and Chesmar Homes and GBRA sought 460,000 gpd of land application on 117 ac under WQ0016516001, with a SOAH preliminary hearing set for Oct 12, 2026 and the Comal River, the Edwards Aquifer and wells among the issues raised [34, 35]. The city's market context is in this post on the San Antonio airport expansion.
Site factors
- Recharge features and impervious cover. The ERZD site development plan shows recharge features, floodplain preservation areas and the impervious cover percentage, so the layout's paving and roof area are measured against the SAWS category from the first sheet [16, 2].
- Buffer zones. Floodplain buffer zones take no impervious cover, and a drainage area buffer zone takes 10% at most [8].
- Fuel and hazardous materials. Tanks in the recharge and transition zones carry a SAWS fee, and uses that produce or store hazardous materials are restricted in the ERZD [1, 7].
- Flood hazard areas. Where they apply, building permit site plans show flood hazard areas and design flood elevations (City Code Sec. 10-8(b)(6)) [17].
- Water supply. No permit issues "where there is not a supply of approved water for domestic or fire protection use" (Sec. 10-6(l)) [17].
- Grease interceptors. Food service sites route all fats, oils and grease fixtures to an exterior interceptor (Sec. 34-526(b)), pumped at least every 90 days and within 2 working days of reaching 25 percent of wetted height (Sec. 34-527(b)), so the interceptor needs truck-accessible ground [36].
- Hill Country roads and lots. Bandera County requires 60 ft of right-of-way on collector and local roads and 100 ft on arterials (Regs. 6.1.1), and lots created for sale are at least 10 acres with a well and on-site sewage, 5 acres with public water and on-site sewage, and 0.5 acre with public water and sewer (Regs. 8.1.1 to 8.1.3) [6].
- Lighting. Boerne's Buc-ee's approval required lighting with shielded fixtures, and lighting compliance was a recurring hearing theme [15].
What the preliminary plan carries in San Antonio
The preliminary site plan carries the layout the zoning application, the ERZD site development plan and the HDRC conceptual review respond to: building footprints, drives, parking, pads and yield, with a site data table that reports the impervious cover percentage against the SAWS category [16, 2]. For a conversion, City Code Sec. 10-8(a)(1) requires a design professional for the building permit set of every Group A (Assembly) occupancy [17]. In Bandera County, the optional Sketch Plan is defined in 2.2.27 as "A map showing a potential subdivision of land not required to be drawn with precision," and the rules set no requirements for its content (Section 3.2), while the surveyor and engineer of record prepare the Preliminary Plan and the sealed road and drainage plans [6].
Developers use the preliminary plan to choose the site, to have a general contractor price it, to show a lender and to raise capital; the engineer of record then adds grading, drainage, water quality, utility and access design and prepares the sealed sets. The site plan consultant and site plan services pages explain how the studio works with the engineer and architect of record, 3D renderings answer the elevation and material questions a historic review asks, the case studies show the method on model projects, and service areas lists every metro covered.
Frequently asked questions
Does the ERZD change my zoning in San Antonio?
Yes. It works as an overlay suffix on the base zone, and rezoning procedures apply to it (UDC Sec. 35-521) [1].
What is the impervious cover cap in San Antonio's ETJ recharge zone?
15% for single-family, multifamily and commercial uses under SAWS Category 3 (Ordinance 81491) [2].
How long is TCEQ's review of an Edwards Aquifer application?
90 days once the application is administratively complete (30 TAC 213.4(e)); that is TCEQ's technical review period, not a city site plan approval [11].
Can I open a restaurant in a C-2 district without a rezoning?
Yes. The city lists restaurants as permitted in NC (with a 3,000 SF building cap), C-1, C-2 and C-3; the office districts O-1 and O-2 need a rezoning [4].
Is there a parking minimum in downtown San Antonio?
How often does the HDRC approve requests?
The Office of Historic Preservation states that over 95% of requests to the HDRC receive approval; the commission meets the first and third Wednesdays of the month [5].
Can Bandera County hear a preliminary plat and a final plat at the same meeting?
No. The Preliminary Plan, Preliminary Plat and Final Plat are considered consecutively, and not more than one stage at the same Commissioners Court meeting (Regs. 3.1.4) [6].
Sources
- 1)Unified Development Code Sec. 35-521, Edwards Aquifer Recharge Protection (via elaws), City of San Antonio (text via elaws). Accessed 2026-10-10.
- 2)Aquifer Protection Ordinance, San Antonio Water System. Accessed 2026-10-10.
- 3)Slow Growth Impacts Nation's Largest Counties Hardest (CB26-56, Vintage 2025 estimates), U.S. Census Bureau. Accessed 2026-10-10.
- 4)Examples of Uses Permitted (updated 08/20/21), City of San Antonio Development Services Department. Accessed 2026-10-10.
- 5)Historic and Design Review Commission page, City of San Antonio Office of Historic Preservation. Accessed 2026-10-10.
- 6)Subdivision and Land Development Regulations (revised through August 25, 2022; file dated January 11, 2024), Bandera County. Accessed 2026-10-10.
- 7)Unified Development Code Sec. 35-332, ERZD Edwards Recharge Zone District (via elaws), City of San Antonio (text via elaws). Accessed 2026-10-10.
- 8)City Code Chapter 34, Article VI, Division 6, Aquifer Recharge Zone and Watershed Protection (via Municode), City of San Antonio (text via Municode). Accessed 2026-10-10.
- 9)Edwards Aquifer program counties, 30 TAC Chapter 213 (marked agenda), Texas Commission on Environmental Quality. Accessed 2026-10-10.
- 10)Edwards Aquifer Protection Plans, Texas Commission on Environmental Quality. Accessed 2026-10-10.
- 11)Edwards Aquifer application cover page, 30 TAC 213.4(e), Texas Commission on Environmental Quality. Accessed 2026-10-10.
- 12)Wilson County Infrastructure Requirements for Lodging and Recreational Vehicle Park Developments, Wilson County. Accessed 2026-10-10.
- 13)Zoning application (with plan amendment), City of San Antonio Development Services Department. Accessed 2026-10-10.
- 14)Permits, Comal County. Accessed 2026-10-09.
- 15)Buc-ee's Project Briefing (August 2025), City of Boerne. Accessed 2026-10-10.
- 16)Unified Development Code Appendix B, Sec. 35-B105, ERZD documentation (via elaws), City of San Antonio (text via elaws). Accessed 2026-10-10.
- 17)Chapter 10, Building-Related Codes, effective May 1, 2025, City of San Antonio Development Services. Accessed 2026-10-10.
- 18)Ordinance 2025-01-30-0075, City of San Antonio. Accessed 2026-10-10.
- 19)City Council Zoning and Land Use session agenda, January 25, 2024 (Spanish edition), City of San Antonio. Accessed 2026-10-10.
- 20)Zoning Commission meeting agenda (meeting 6526), City of San Antonio. Accessed 2026-10-10.
- 21)Zoning Commission meeting agenda (meeting 7273), City of San Antonio. Accessed 2026-10-10.
- 22)Steps to Obtain an OSSF Permit, Comal County. Accessed 2026-10-10.
- 23)City Code Sec. 4-6, distances from church, school or hospital (via elaws), City of San Antonio (text via elaws). Accessed 2026-10-10.
- 24)Information Bulletin 541, IDZ parking, City of San Antonio Development Services. Accessed 2026-10-10.
- 25)Unified Development Code Sec. 35-526, parking and loading standards (via elaws), City of San Antonio (text via elaws). Accessed 2026-10-10.
- 26)Sidewalk Cafe General Application, City of San Antonio Center City Development and Operations. Accessed 2026-10-10.
- 27)Denser development with less parking greenlit for San Antonio's new Green Line rapid bus corridor, KSAT. Accessed 2026-10-10.
- 28)Historic and Design Review Commission meeting minutes, September 4, 2024, City of San Antonio Office of Historic Preservation. Accessed 2026-10-10.
- 29)2024 Annual Building Permits highlights, U.S. Census Bureau. Accessed 2026-10-10.
- 30)This new $38M Buc-ee's travel center will finally be built after 10 years of planning, AOL (secondary). Accessed 2026-10-10.
- 31)Neighbors to controversial S.A.-area Buc-ee's demand transparency, MySA. Accessed 2026-10-09.
- 32)HDRC approves new Rosario's restaurant plan over neighbor's objections, San Antonio Report. Accessed 2026-10-10.
- 33)Response to comments, Gram Vikas Partners wastewater permit WQ0015990001, Texas Commission on Environmental Quality. Accessed 2026-10-09.
- 34)Calendar of Public Meetings and Hearings on Permitting Cases, Texas Commission on Environmental Quality. Accessed 2026-10-09.
- 35)TCEQ to hold public hearing for proposed wastewater permit in New Braunfels, Community Impact. Accessed 2026-10-09.
- 36)Fats, Oils and Grease Ordinance 2011-05-12-0378, San Antonio Water System. Accessed 2026-10-10.