Category: Chicago

Comment to Chicago’s committee on zoning about expanding ADUs

This doesn’t fully match with what I spoke at the Chicago City Council committee on zoning, landmarks, and building standards on April 16, 2024 (meeting agenda), because it was written for about two and a half minutes but due to the high number of public commenters Vice Chair Lawson (44th Ward) reduced everyone’s maximum speaking time from 3 minutes to 2 minutes so I made some on-the-fly cuts. Ordinance O2023-2075.

My name is Steven Vance. I am a Chicago resident and a land use consultant. In two weeks the city will reach the three-year anniversary of when Chicagoans could start applying for building permits to build accessory dwelling units, otherwise known as ADUs. Locally we call them garden apartments and coach houses.

In that time, the city has permitted approximately 237 projects comprising 275 new ADU homes. 75% of these are or will be in basements, and a little less than 20% are or will be in backyard or “coach” houses. 

11% of these homes are required to be rented at affordable rates set by the Department of Housing each year.

That’s 271 new homes that are or will be providing housing for family members, providing new income for property owners, and picking away at the city’s housing shortage of 120,000 homes. But the opportunity is not available to everyone, and the number of ADU permits issued each quarter has been declining since December 2022. 

The number of ADU permits has been declining. I include the graph here to illustrate my point but I did not present the graph during my comment.

City Council adopted five pilot areas, a limitation that doesn’t need to stick around. Hundreds of currently interested property owners are prohibited from building an ADU. Their current alternative is to undertake a costly zoning change process to gain the privilege of building one or two more units on their properties. (However, shoutout to the few alderpersons who facilitate this process on behalf of their constituents.)

I operate Chicago Cityscape, a real estate information website that also has advice on building ADUs and a tool to look up if a property is in an ADU pilot area. 

As of last week, people have looked up 815 addresses in 48 wards…but…70% of those addresses were not in a pilot area and those people will not be able to build an ADU at this time.

I believe those permitting and address lookup statistics show that ADUs, while representing less than 3% of new construction homes, are popular. They allow for Chicagoans to modify their properties to age in place, fund renovations and property taxes, or move a family member to be closer. Now is the time to expand this benefit to all of Chicago and I urge the City Council to drop the geographic ban as soon as possible.

Finally, Mayor Johnson’s Cut The Tape initiative includes citywide ADUs as a phase 2 strategy, so ADUs are something City Council should support. [This part was added last second.]

The best ideas from Mayor Johnson’s “Cut The Tape” initiative

Mayor Johnson and staff in the Mayor’s Office announced today at the Chicago Cultural Center the finality of administrative and legislative strategies – called “Cut The Tape” – developed for the development process executive, EO2023-21.

What I think makes the “best” are the strategies that I believe will increase housing abundance (a phrase that made it into the vision statement) and reduce development costs. To explain why I picked it, I added a “Why?” statement to each.

A good portion of the 107 strategies are solutions to issues that I’m not familiar with [1], and for now I will be skipping those until I learn more about them.

The best publicly-visible strategies

  • 4. Design a process for expedited review of affordable housing development projects. [Why? Affordable housing already has high costs, some of which are extended carrying costs due to the lengthy review and approval process.]
  • 7. Convene a working group to explore consolidating the Community Development Commission (CDC) and Chicago Plan Commission (CPC) into a single body or to have joint meetings to streamline processes. [Why? Certain project types have to be approved by both commissions, which have different schedules, different application and documentation standards. Approving a project in fewer meetings saves time and effort from staff and applicant.]
  • 9. Propose that the City only present City-owned land sales to the Chicago Development Commission (CDC) if the land has acquisition, remediation, or vertical construction that is subsidized with TIF dollars. [Why? ChiBlockBuilder and similar sales should be able to be done with fewer necessary approvals. City Council would still have to approve these sales.]
  • 17. Reduce the number of internal design review meetings from 3 to 1 and assess how to best engage DPD’s Committee on Design going forward. [Why? Fewer meetings is better – I’m not sure what else to say.]
  • 20. Finalize pre-approved designs to create faster options to build more affordable housing. [Why? Come Home Chicago was a pretty good idea from the Lightfoot administration and it needs a conclusion, in the form of a catalog of pre-approved designs that home builders can license to get permits faster. If the post-TIF Bond gets adopted by City Council then the pre-approved plans will coincide with a missing middle initiative called “pad ready” in the Bond that will prepare city-owned lots for construction of houses in the plan catalog. Learn about how the pre-approved plan program in South Bend, Indiana, is going.]
  • 28. Expand the pilot program for cash advance payment options. [Why? A lot of grant programs are only paid as a reimbursement which makes it harder and sometimes more expensive for small businesses to execute on the reason they’re receiving the grant; this program would offer cash ahead of time with appropriate guardrails to protect potential taxpayer loss.]
  • 59. Expand the City’s Encumbrance Ordinance to enable the clearing of City fines and fees from City-owned vacant lots; to include any debt owed to city, including but not limited to: water or sewer assessment; money owed to the City pursuant to a court order or an order from the Department of Administrative Hearings (DOAH); or demolition liens. [Why? The city has liens on properties it owns, due to acquisition since those liens, for unpaid water and sewer bills, which it expects the acquirer of city-owned land to pay rather than the entity that generated the debt. In many cases, it’s faster and cheaper for the new owner to pay the old debt that belongs to someone else.]
  • 67. Eliminate Zoning Board of Appeals (ZBA) approval of a special use permit to open a hair salon, barber shop, body art shop, or nail salon. [Why? This one makes it into my top three. I don’t think there’s a valid argument for these types of businesses to have to obtain a “special use” from the ZBA. It’s regressive, it wastes everyone’s time, and the ZBA approves every single one of them.]
  • 68. Explore Universal Affordability Preferences that would allow buildings to add more housing by-right without triggering a planned development, but only if the additional units are affordable. [Why? Affordable housing – really, any new housing – should not be subject to community approval, and this would help overcome aldermanic privilege/prerogative while also generating more housing.]

List continues below

  • 69. Revisit zoning code elements that functionally require all shelters and transitional housing developments to seek approval from ZBA, regardless of building size, form, or underlying zoning designation. [Why? Shelters are necessary, should not be subject to local community approval, and the current system is ridiculous in that a shelter can fail to be approved because a ZBA member seat is unappointed or a member and an alternate didn’t show up to a meeting.]
  • 70. Amend the Chicago Zoning Ordinance to allow applicants for Type 1 zoning changes to incorporate requests for variations and administrative adjustments into Type 1 zoning change applications – eliminating the duplicate review processes. [Why? It lowers the cost of doing business in the city, and lowers the cost and speeds up the acquisition of certain approvals that the zoning code mandates. EXAMPLE: developer proposes a building that needs a 5′ reduction in the required rear setback; rather than see two different boards or committees and prepare two different sets of documentation and analysis, the developer bundles the setback variation request into the “Type 1” zoning change request. IN FACT, this strategy is complete and it’s been in use since February’s zoning committee meeting.]
  • 76 and 77. Allow commercial-to-residential conversions of ground floors while exempting those conversions from additional residential parking requirements. + Allow ground floor residential uses on commercial corridors with excessive vacancy. [Why? Housing abundance, and this would enable more accessible homes, a priority of AARP, Access Living, and others.]
  • 79. Pass ordinance to allow for up to four issues to be heard as administrative adjustments before a ZBA hearing is required. [Why? The documentation burden and the required “findings of fact”analysis for appearing in front of ZBA is unnecessary for the kinds of changes that really should be approved as administrative adjustments.]
  • 80 and 81. Create an interdepartmental working group to streamline special uses and variations by shifting most applications to administrative review processes, while retaining the ZBA’s more in-depth evaluation for applications that warrant an increased level of public scrutiny. + Allow multiple administrative adjustments to not be reviewed as variations, allowing certain parking reductions by right, and investigating whether other variations needed for housing projects may be addressed via administrative adjustment. [Why? Basically the same reason as 79.]
  • 82. Eliminate minimum off-street parking requirements on new developments citywide. [Why? Parking requirements increase development costs, are carbon-intensive, facilitate higher levels of car ownership in urban areas, and “free” spaces causes more traffic.]
  • 83. Remove zoning barriers to City’s Non-Congregate Shelter acquisition program, allowing existing buildings to be repurposed as shelters or transitional residences. [Why? Zoning shouldn’t be used to inhibit new housing, especially for the most vulnerable Chicagoans – see also 69.]
  • 103. Support third-party organizations to develop technical assistance and capacity building programs for emerging and MWBE developers. [Why? Chicago benefits if more people are capable of developing property – see CEMDI for an example of a capacity-building program.]

There are a ton of additional strategies that are largely internal processes but with clear benefits to city staff and the applicants that represent what’s sometimes meant as “streamlining” a process. For example:

  • 46. Explore technology platforms that will allow departments to better organize and track closing documents, beyond the current exchange of documents via email
  • 52. Explore the feasibility of using electronic signatures on contracts.

Honorable mentions

  • 56, which I would like to know more about: “Align Chicago Construction Codes with current national model codes and standards, including modernizing the Mechanical Code in 2024 and Building Code in 2025.”
    What is in the current versions of the International Building Codes that have been adopted since Chicago’s IBC 2018 that would reduce housing costs, or make it easier to build housing?
    According to a contributor, items in the ICC’s mechanical and plumbing codes should make construction more affordable, and updating to the latest IBC allows for more mass timber.
  • 78. Explore options to post DPD’s special use recommendations online at ZBA website seven days before hearing date. [Why? Transparency.]
  • 86. Explore options for ZBA to post applications, plans, findings of fact, and staff recommendations to its website. [Why? Transparency.]

Missing

Other land use and zoning reforms that are on the level of “eliminating parking mandates citywide”:

  • Allowing accessory dwelling units (basement units and coach houses) citywide.
  • Allowing two and three-flats in all residential zoning districts.

Want to organize around these policy changes? Join Urban Environmentalists Illinois.

[Notes]

[1]. For example, I am not familiar with what this strategy is referring to, or the impact it could have, but I trust – based on the overall quality, expansiveness, the expertise of the focus groups who were consulted, and personal familiarity with most strategies – that it’s important: “47. Consolidate DPD Capital Grant funding requirements, structures, and sources of three programs into two grant tracks: Medium and Large”.

Why Chicago should have a rental registry

This is a publicly accessible scratchpad of what I’m thinking. As I already said, Chicago should have a rental registry, a database of dwelling units that are rented to tenants, for at least two reasons:

  1. The city can know things about the rental units, including how much they cost, where they are, and if any are vacant and could be occupied if only people knew they were available and how to get in touch with the owner. 
  2. The city can know who the owners are and contact them to issue citations or advise them, or fill out for them, emergency rental assistance during pandemics and other times of necessity.
Who owns and rents each of these buildings, and are they providing a quality apartment to their tents?

Rationale for a rental registry

  • It could improve the quality of housing by forcing renovations when tenants are not making complaints due to the potential for retaliation or eviction.
  • Chicago’s complaint-based inspection system misses a lot of life-threatening situations (Illinois Answers Project, article 1, 2023; and Illinois Answers Project, article 2, 2023)
  • Tenants should be able to know who owns the property they rent. Under the current data regime in Illinois, it’s unreasonable to expect a tenant to know how to look up this information. Of course, someone could use my Chicago Cityscape platform to look up property ownership and transfers.
  • Chicago could put bad landlords out of business (Illinois Answers Project, 2021).

What do you think forms the basis for Chicago to have a rental registry?

Why courtyard buildings aren’t allowed in Chicago anymore

Chicago Urbanist Twitter was abuzz this month when renderings of a proposed construction courtyard building were published (they’re shown below), given that the historical building typology hadn’t been built in Chicago in decades. Some wondered if this revered local design was making a return.

The post is probably better titled “how it is that courtyard buildings aren’t built in Chicago anymore” as I don’t know why the codes changed in such a way to, effectively, do away with the housing typology. And it’s the second time I’ve evaluated the feasibility of building a specific housing typology; see my post about cottage clusters.

I don’t think there will be a resurgence or resurrected trend in building courtyard buildings in Chicago, because of how the city’s building and zoning codes inhibit them. At the end I discuss how Chicago might get courtyard buildings to return.

Chicago has several variations of courtyard buildings

Common variations of Chicago courtyard buildings include:

  1. Large inset front courtyard (U-shaped) buildings
  2. Buildings with rear courts, often with exterior unenclosed porches or a small rear yard and possibly a garage (I speculate providing a space for one or two cars in a 20-unit building was meant for the building owner)
  3. Side court buildings
  4. S-shape and multi-court (which are kind of modular)

People like Chicago courtyard buildings

To describe the Chicago courtyard building, I compiled reasons why people like courtyard buildings, especially the type with the front courtyard based on conversations I observed on Twitter and by asking members of Urban Environmentalists of Illinois.

  • They look nice, with all of the landscaping visible from the sidewalk. Landscaping isn’t relegated to the roof and can be seen by the public.
  • Everyone’s unit has a designated nice view, as every unit faces the inner court. Compare this to a double-loaded corridor where about half the units will face the street and the other half may face the alley.
  • The unit layouts are some of the best; the apartments have lots of natural light and all rooms have windows. The units are often “dual aspect” and with windows on two walls the unit can have cross ventilation. This may be a subjective, though, as the use of constant mechanical air flow with filtering and exhausting may provide some with greater comfort. Additionally, the need for cross breeze is less necessary given air conditioning and low-cost energy.
  • Courtyard buildings enable many different unit types within one development (studios and 1-3 bedrooms), which means there can be a decent mix of types of people (families and singles and couples.) This is unlike a building using a double-loaded corridor floor plan, which often place multi-bedroom apartments at the corners.
  • Most units are pretty quiet since some of the unit’s layout is not directly against street, not too noisy.

Learn more about floor plan design significance by listening to this Odd Lots podcast interview with Stephen Smith and Bobby Fijan.

I also feel that a courtyard by building’s layout is similar to a point access block’s (i.e. two or three units per floor per stairwell). Even though the courtyard buildings can be large, their multiple cores help them appear “small-scale and homey compared to having long hallways. You actually know people in your stairwell, not a bunch of strangers” (Jesse O.). (This also means they utilize space more effectively than double-loaded corridor buildings, which has impacts on cost.)

Mike Eliason is a major proponent and promoter of point access blocks because they offer a superior layout; his book, to be published this year, will argue that, but you can get a preview of his reasonings by reading through his Twitter (like this tweet) or reading the point access block policy brief that his architecture firm wrote for the City of Seattle.

If you’d like to learn more about the courtyard building’s history, Moss Design, a local architecture firm, explores the advantages and history of courtyard buildings in Chicago (the post is from 2014).

What do you like about courtyard buildings?

Zoning code conflicts

Courtyard buildings are difficult or impossible to build in Chicago for many of the reasons that I described in a previous post about how to amend the zoning code to allow “cottage courts” in Chicago. They are repeated here:

  1. Rear setbacks would need to be reducible, preferably without the need for a variation from the Zoning Board of Appeals. Because the houses are oriented to face a common green space at the interior of the lot (not at the front or rear of the lot), the rear of the house may be close to the rear property line, violating the rear setback standard of ~30 feet. 
  2. Side setbacks would need to be combinable or eliminated as a requirement for courtyard buildings because the unbuilt space on the property that is normally required for a rear yard is concentrated in the interior court pushing the building to the edges of the property.
  3. Parking requirements would need to be more flexible, both in quantity and in design, otherwise the parking areas would occupy a third to half of the property, minimizing the space that can be used for the interior court. To maximize the shared green space, parking requirements should be reducible for this housing type. The Chicago TOD ordinance that reduces parking requirements may be relevant here, as it now applies in RM-5, and higher, residential zoning districts (notably rare).
  4. Minimum lot area per unit standards can likely be met cost-effectively in the less common RM-5 and higher zoning districts. The most common residential zoning districts in Chicago are RS-3 and RT-4. The RS-3 zoning districts do not allow more than two units on a lot; in RT-4 zoning districts the developer would have to assemble so many lots to be able to get the unit count necessary to make such a building’s construction cost-effective yet the land acquisition might be so costly as to make the project infeasible.

Walk around Rogers Park, Lakeview, and Hyde Park – where it seems the most courtyard buildings were built – and you’ll see that most of them don’t have any car parking. And the ones that do certainly don’t have as many to meet current car parking requirements.

Building code conflicts

Note that “IANAA” (I am not an architect) and my expertise on building codes is always quite limited.

Exits and stairs. The Chicago building code generally requires a minimum of two stairs for buildings of an occupancy classification of R-2 (multifamily with four or more units, not including shelters); see section 1006.3.2 in the Chicago building code for info about two-exit standards.

The two exits must also be within a minimum and maximum distance apart from each other; this standard ends up requiring a corridor between the two stairs so that each unit can access either stair. This corridor eliminates rentable area and decreases the floor plan’s efficiency (a metric for architects and developers that affects the pro forma).

In the new construction courtyard building’s renderings at the top of the post, there are three interior stairs! See also the Standard 8-3 comment below.

Section 1006.3.3 in the Chicago building code outlines the single exit (single stair) conditions. Without going further into alternatives and exceptions, a three-floor three-flat can be a single stair building as long as the third floor doesn’t exceed 1,600 s.f. of floor area and the house has a sprinkler system ($$). You read that right…Chicago allows single stair for buildings with 1-3 units and 1-3 floors.

Existing courtyard buildings in Chicago that don’t have a second interior exit stair will then have an exterior exit stair, often connected to porches; this example has a minimal shared porch attached to the exterior exit stair at a courtyard building.

There are limitations on the use of exterior stairs for exiting requirements and I’m unable to articulate their impact on size or orientation. They cannot be used for exiting on floors that are 45 feet above grade, and cannot provide “more than 50 percent of the number and minimum width or required capacity of means of egress components” (1027.2.1). There are also standards on the exterior stair materials.

Long corridor. The minimum corridor length and the sometimes-extra stairs require a bigger building footprint (increasing construction cost compared to a building without corridors, like the point access block), which is already constrained by parking mandates and inexplicable zoning code setback requirements. See section 1007.1.1 in the Chicago building to learn about how far apart exits need to be.

It’s not actually the multiple stairs that are the space hog…it’s the corridor that’s required to connect the multiple stairs.

Setbacks. Fire separation distance is different than a zoning setback. The building code allows buildings to abut (touch) adjacent buildings but the fire protection standards on that side of the building are increased. No windows could be built on a wall that has zero setback, so natural light and vent requirements for bedrooms would have to be provided through light courts and placing bedrooms at the front or rear of the building.

A quick note about elevators: it’s my understanding that an elevator is not required if the required accessible Type A units (20 percent) are at grade and no floors above the ground floor contain building amenities (1104.4).

Do you know of some other regulatory standards that affect the development feasibility of courtyard buildings and point access blocks in the United States?

Return of the courtyard building in Chicago?

As I said at the beginning, I don’t think the one proposed new construction courtyard building will lead the resumption of the courtyard building in Chicago. There are the conflicts in the codes that I think would need to be significantly modified to facilitate new courtyard building construction.

I also believe that there are other factors: who develops, who designs, who lends, and who would live there that matter. These may be more influential in whether a new courtyard building gets built in 2024 than the zoning and building code conflicts; in other words, what if the city tweaks those codes and no new courtyard buildings get built?

I’m thinking of the “Standard 6-3” building I promoted, a typical design in Chicago that was re-legalized in some areas of the city when the Connected Communities Ordinance was passed in 2022. That zoning code amendment allows for a six-flat (back to back apartments on three floors) to be built on a standard size lot with minimal or no car parking. To my knowledge, though, none have been built.

Then there’s the circumstance that the double loaded corridor makes a lot of financial sense for developers and construction companies; the identical unit layouts are easy to design and build and the density of units is quite high. Plus the floor plate efficiency is significantly higher in a DLC compared to a single-loaded corridor (which Chicago has some of, in the form of “California style” apartments). DLC buildings often have a much greater proportion of studios and one-bedroom units, which, on a per-square-foot basis, collect more rent than larger units.

To comment on those factors of developer, designer, lender, and tenant, I would defer to asking those people, which is beyond the scope of this blog post. Conveniently, a developer of smaller-scale multifamily buildings, Coby Lefko, wrote a guest article on Noah Smith’s blog that I think addresses some of the friction to develop something like a courtyard building.

Coby writes, “Even while recognizing the need for comprehensive solutions, too many urbanists have ignored the importance of finance [emphasis added] in charting a different course for the future.” The thrust of the article is that cities need small developers but it’s hard to be a small developer.

I think many urbanists, myself included, opine on development in ways that fail to reflect lacking the knowledge of experience of having actually built something. I’m trying to gain more knowledge about it; recently, I nominally learned how to read and write a pro forma, a special spreadsheet that developers use to gauge the cost and benefit of a specific proposal.

As more of us consider land use reforms to allow for housing abundance in Illinois, let’s also discuss “supporting new courtyard buildings” – they provide desirable unit layouts, small and family-sized apartments, cozier neighbor arrangements, and Chicagoans just really like them!

Chicago City Council could end up voting to ban new dollar stores

Update: This ordinance passed out of licensing committee on Monday, January 22, 2024. Also, the link to the ordinance is not working and I can’t find another way to link to it on the City Clerk’s legislation database. The version that passed out of committee reduces the radius from 2 miles to 1 mile and reduces the threshold for fresh and frozen food to avoid the radius minimum from 40 percent to 10 percent.

Update 2, February 22, 2024: A substitute ordinance was passed by City Council yesterday; the thresholds described in the paragraph above were established but the distance separation clause was amended so that only dollar stores of the same owner are banned within one mile. In other words, and this is dependent on the definition of “controlling person” in the code at section 4-4-005, a Dollar General could not open within one mile of a Dollar General or a Dollar Tree, but a Family Dollar could. A new map is shown at the end.

Ald. O’Shea (19th Ward) has proposed an ordinance with 35 cosponsors that would ban dollar stores within two miles of another dollar store and within 1/8th mile of an “R” zoning district. The ordinance number is O2023-0004978; read the PDF of the proposed ordinance.

The ordinance would amend the zoning code in chapter 17 as well as add business license regulations in chapter 4 of the Municipal Code of Chicago. The new business licensing section would establish strict rules on “excessive loud noises” and trash accumulation at dollar stores, and even regulate what people outside the store could be doing, as well as require a site plan review by the planning and transportation departments (something usually only required when there is a driveway, drive-through, or larger development).

The city codes would include dollar stores under the new definition of “small box retailer”, which excludes Walgreens and gas station mini marts.

Specifically, “small-box retailer means a retail store (a) with a floor area between 5,000 and 17,500 square feet; (b) that sells at retail an assortment of physical goods, products, or merchandise directly to the consumer, including food or beverages for off-premises consumption, household products, personal grooming and health products, and other consumer goods; (c) that continuously offers and advertises a majority of the items in their inventory for sale at a price less than $5.00 per item; and (d) that does not: (i) contain a prescription pharmacy, (ii) sell gasoline or diesel fuel, (iii) primarily sell specialty food items, or (iv) dedicate less than 5% of shelf space and display areas to food sales.”

The proposal’s purpose is spelled out in the preamble, which makes some judgements about the prevalence of dollar stores in Chicago.

WHEREAS, The City of Chicago (“City”) is a home rule unit of government under Article VII, Section 6(a) of the 1970 Constitution of the State of Illinois and, as such, may exercise any power and perform any function pertaining to its government and affairs, including, but not limited to, the power to regulate for the protection of the public health, safety, and welfare; and

WHEREAS, There is a proliferation of small-box retailers, such as Dollar Tree, Family Dollar (which is owned by Dollar Tree), and Dollar General, in urban areas, including the City, where small-box retailers are clustered in and around South and West Side neighborhoods; and

WHEREAS, Although small-box retailers can fill a need in communities lacking basic retail services, growing evidence suggests small-box retailers are not merely a byproduct of this economic distress, they can often be a cause of it; and

WHEREAS, By saturating communities, particularly majority-Black urban neighborhoods, with multiple stores, small-box retailers’ business strategy often makes it impossible for independent and local grocery stores to open, or, indeed remain open, in a community; and

WHEREAS, Small-box retailers are not a meaningful alternative to local grocery stores, often devoting minimal, if any, floor space to fresh, wholesome foods, and offering low-cost, single serving, highly processed foods that are in actuality much more expensive per ounce; and

WHEREAS, In addition to these negative economic impacts, small-box retailers also tend to attract higher inc dences of crime, theft, and other negative effects on the public health, safety, and welfare, suc as littering and the accumulation of waste far exceeding the dumpster space provided by small-box retailers; and

WHEREAS, Regulating small-box retailers is necessary, desirable, and in the public interest by promoting stronger, more resilient neighborhoods and protecting the public health, safety, and welfare of our Cit ; now, therefore:

Natalie Moore wrote a column in the Chicago Sun-Times about some of the impacts of dollar stores in the city.

Ramifications

If this ordinance went into effect, new dollar stores would only be allowed in the green areas of Chicago. Additional areas would open up if the proposed dollar store would dedicate ≥40 percent of shelf space to fresh or frozen food. This map only considers “Big Dollar” stores and not independent dollar stores that might meet the parameters in the proposed ordinance.

The map below shows 150 locations of Dollar Tree, Dollar General, and Family Dollar stores. Family Dollar is part of Dollar Tree.

The green areas show the parts of Chicago where a new dollar store that follows the default “two mile minimum” rule would be allowed. The proposed ordinance has a provision that if 40 percent or more of shelf space is dedicated to fresh or frozen food then that new dollar store only has to be one mile away from any other dollar store.

It’s possible that dollar store companies could erect stores that are smaller or larger than the floor area standard in the proposed ordinance that would otherwise capture them into the “small box retailer” definition.

A map based on the approved substitute ordinance, showing 1 mile buffer areas, is shown below.