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MEMORANDUM
Date: June 6, 2025
To: Carmel Plan Commission
From: Adrienne Keeling
Re: Docket No. PZ-2025-00101 OA
Group Home Ordinance Amendment
Enclosed is a Draft UDO Amendment for the below item. If you have any questions, please call 571-2417.
Docket No. PZ-2025-00101 OA: Group Home UDO Amendment
The applicant seeks to amend the UDO pursuant to City Council Resolution 02-03-25-07, which directs the
Plan Commission to consider amendments to UDO Sections 5.72, 9.08, and 11.02 in order to revise the
standards, approval process, and definitions related to Group Homes. Filed by the Department of
Community Services on behalf of the Carmel City Council.
Background:
The Carmel City Council unanimously passed Resolution CC-02-03-24-07 on May 5, 2025. This Resolution
directs the Carmel Plan Commission to consider and make a recommendation on amendments to Articles 5.72,
9.08, and 11.02 of the Unified Development Ordinance.
The Council’s proposed amendments are reflected in the attached redline document which was adopted as
Exhibit A of their Resolution.
Required Timeline and Action:
Pursuant to Indiana Code 36-7-4-607(c), Council Resolution CC-02-03-24-07 specifies that the Plan
Commission has sixty (60) days to hold a public hearing (Friday, July 4, 2025), and make a recommendation on
the proposal not later than sixty (60) days after the Commission holds the public hearing (Saturday, August 16,
2025).
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SPONSOR(S): ___________ 1
2
ORDINANCE Z-____-__ 3
AN ORDINANCE OF THE COMMON COUNCIL OF THE CITY OF CARMEL, 4
INDIANA, AMENDING THE UNIFIED DEVELOPMENT ORDINANCE 5
Synopsis: This Ordinance amends Article 5.72 of the Unified Development Ordinance (the 6
“UDO”) to require that the applicant obtain a license from either the Indiana Division of Mental 7
Health and Addiction or the Indiana Division of Disability and Rehabilitative Services. 8
Additionally, it amends Article 9.08 of the UDO to grant the Board of Zoning Appeals the 9
exclusive authority to approve or deny special use exceptions for Group Homes rather than a 10
Hearing Officer. Article 9.08 is also amended to limit the number of unrelated residents of a 11
Group Home to not more than eight (8) persons. Finally, it amends Article 11.02, specifically the 12
definition of “Group Homes,” to require that they must be licensed Indiana Department of 13
Mental Health and Addiction or the Indiana Division of Disability and Rehabilitative Services, 14
and amends the definition of “Dwelling, Two Family” to expressly exclude Group Homes. 15
WHEREAS, pursuant to Ind. Code §36-7-4-607 the Common Council of the City of 16
Carmel (the “Common Council”) is authorized to amend the text of the Unified Development 17
Ordinance; and 18
WHEREAS, Article 5.72 of the Carmel Unified Development Ordinance provides Use-19
Specific Standards for Group Homes; and 20
WHEREAS, the Common Council desires to amend the text of Article 5.72 of the Carmel 21
Unified Development Ordinance to require Group Homes housing persons with developmental 22
disabilities and Group Homes housing persons with psychiatric disorders or addictions to obtain 23
and maintain licenses with Indiana Division of Disability and Rehabilitative Services or the 24
Indiana Division of Mental Health and Addiction, respectively; and 25
WHEREAS, the Common Council also desires to amend the text of Article 5.72 of the 26
Carmel Unified Development Ordinance to restrict the number of Group Homes permitted within 27
a specific geographic area; and 28
WHEREAS, the Common Council desires to amend the text of Article 9.08 of the Carmel 29
Unified Development Ordinance so that Special Exceptions for Group Homes are approved 30
exclusively by the Board of Zoning Appeals, with the opinion of the Director of Community 31
Services functioning solely as a staff recommendation; and 32
WHEREAS, the Common Council desires to limit the number of unrelated residents of a 33
Group Home to not more than eight (8) persons; and 34
WHEREAS, the Common Council desires to amend the text of Article 11.02 of the Carmel 35
Unified Development Ordinance to provide that Group Homes housing persons with 36
Developmental Disabilities must be licensed by the Indiana Division of Disability and 37
Rehabilitative Services and that Group Homes housing persons with psychiatric disorders or 38
addictions are licensed by the Indiana Division of Mental Health and Addiction; and 39
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WHEREAS, pursuant to Common Council Resolution No. CC-02-03-25-07, the City’s 40
Advisory Plan Commission (the “Commission”) received the Common Council’s proposal to 41
consider and provide a recommendation to the Common Council regarding the proposed 42
amendment to the Special Exception procedures; and 43
WHEREAS, pursuant to Ind. Code §36-7-4-604, the Commission held a public hearing 44
regarding Docket No. PZ-2025-00101 OA on June 17, 2025, after providing public notice thereof 45
as required by law; and 46
WHEREAS, upon completion of the public hearing the Commission voted to make the 47
following recommendation as evidenced by the certification attached hereto as Exhibit A; and 48
WHEREAS, the Common Council now desires to adopt the Amendment in the form 49
included in this Ordinance. 50
NOW, THEREFORE, BE IT ORDAINED BY THE COMMON COUNCIL OF THE 51
CITY OF CARMEL, INDIANA AS FOLLOWS: 52
Section I. Recitals Incorporated. The foregoing recitals are incorporated herein by this 53
reference. 54
Section II. Amend Article 5.72 US-26: Group Home Use-Specific Standards as follows: 55
A. Purpose: It is the purpose of this Section to benefit the general public by minimizing 56
adverse impacts on established residential neighborhoods in the City and the owners and 57
residents of properties in these neighborhoods which may result from the conversion of 58
residential properties to business or institutional uses. However, it is also the purpose of 59
this Section to provide that the City may not refuse to make a reasonable accommodation 60
for a Group Home whenever such an accommodation would not impose undue financial or 61
administrative burdens on the City or require a fundamental alteration in the 62
Comprehensive Plan. 63
64
B. Special Exception Eligibility: A Dwelling located in a residential district may be used as a 65
Group Home only if the owner or occupant applies for and is granted a Special Exception, 66
pursuant to Section 9.08: Special Exception (Group Homes and Short-Term Residential 67
Rentals) hereof. 68
69
C. Required Information for Application: Both the initial application and any renewal 70
application for a Special Exception or Improvement Location Permit for a Group Home 71
shall contain primary and secondary emergency contact information, including mailing 72
address, phone number or email address. Upon approval of a Special Exception, emergency 73
contact information shall be shared with the Carmel Police Department. Group Homes 74
housing persons with developmental disabilities shall obtain, comply with, and maintain a 75
license or certification from the Indiana Division of Disability and Rehabilitative Services 76
which shall be included in its initial application. Group Homes housing those living with 77
psychiatric disorders or addictions shall obtain, comply with, and maintain a license or 78
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certification from the Indiana Division of Mental Health and Addiction, which shall be 79
included in its initial application. 80
81
D. Limitations: 82
a. No Group Home in an S1, S2, R1, R2, R3, R4, R5 or UR district shall provide 83
housing for more than eight (8) unrelated persons. 84
b. The term of a Special Exception permit granted to a Group Home shall be for five 85
(5), ten (10), or fifteen (15) years, at the discretion of the Board of Zoning Appeals. 86
The grant of a Special Exception permit provides an exception only to the other 87
requirements of the Unified Development Ordinance. It does not confer a right to 88
lease, sublease, or otherwise use a Dwelling as a Group Home where such use is 89
not otherwise allowed by law, a homeowners association agreement or 90
requirements, any applicable covenant, condition, and restriction, a rental 91
agreement, or any other restriction, requirement, or enforceable agreement. 92
c. Nothing in this Section shall relieve any person of the obligations imposed by any 93
and all applicable provisions of Federal and State laws and the Carmel City Code, 94
including but not limited to those obligations imposed by Indiana tax laws and 95
rules. Further, nothing in this Section shall be construed to limit any remedies 96
available under any and all applicable provisions of Federal or State law and the 97
Carmel City Code. 98
99
E. Reasonable Accommodation: After formal acceptance of an application for a Special 100
Exception for a Group Home, and upon request from the Applicant, the Director of 101
Community Services shall review the application for the purpose of determining whether 102
it would be a reasonable accommodation for the City to grant the Special Exception in 103
order to provide the residents who would be provided services at the Group Home with 104
access to housing that is equal to that of residents who are not in need of such services. In 105
addition to the items listed in Section 9.08(C): Basis of Review hereof, the Director of 106
Community Services shall consider the following: 107
1. Proximity of other Group Homes to the proposed site; 108
2. The number of unrelated persons who will be living in the Group Home, and 109
whether any professional support staff will also be residing there; 110
3. In addition to any residents’ cars, if more than two (2) staff cars will be parked at 111
the Group Home, and whether they will be marked; 112
4. If the Dwelling, existing, modified or new, is similar in design, materials and 113
landscaping as other adjacent and nearby Dwellings; 114
5. Any other exterior indication that the Dwelling will be inhabited by Group Home 115
residents; 116
6. Any undue financial or administrative burdens that would be imposed on the City; 117
and 118
7. If a fundamental alteration in the Comprehensive Plan would be required. 119
Based upon this review, the Director of Community Services may support or oppose 120
the granting of the Special Exception. 121
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122
Section III. Amend Article 9.08(A) General Information as follows: 123
A. General Information: Except for Short-Term Residential and Short-Term Non-Dwelling 124
Rental renewal applications, Special Exception approval by a Hearing Officer of the Board 125
of Zoning Appeals shall be necessary prior to the establishment of a Special Exception, 126
cited by the district regulations herein, or the issuance of an Improvement Location Permit 127
for said Special Exception. A Special Exception shall be considered as an exception to the 128
uses allowed under the Unified Development Ordinance, and thus the original application 129
for a Special Exception shall not generally be entitled to favorable consideration, except as 130
follows: 131
1. A proposed Group Home that complies with the requirements of Article 5.72 where 132
not more than eight (8) unrelated persons will be residents shall generally be 133
entitled to favorable consideration; 134
2. A proposed Group Home that complies with the requirements of Article 5.72 where 135
more than eight (8) unrelated persons will be residents not less than nine (9) nor 136
more than twelve (12) eight (8) or more unrelated persons will be residents shall 137
generally be entitled to favorable consideration, so long as the application is not 138
opposed by the Director of Community Services; 139
3. A proposed Group Home where thirteen (13) or more unrelated persons will be 140
residents shall be entitled to favorable consideration only if the application is 141
supported by the Director of Community Services. 142
Any application for the renewal of a Special Exception that complies with the 143
requirements of Article 5.72 shall generally be entitled to favorable consideration, so 144
long as it is not opposed by the Director of Community Services. A Hearing Officer 145
The Board of Zoning Appeals shall have discretion whether to approve or deny each 146
Special Exception application, with his or her its decision to be based on the basis for 147
review criteria established herein and special and unique conditions pertinent to the 148
site. 149
B. Procedure: 1. Procedure Generally: Whenever an application for a Special Exception 150
within the planning jurisdiction is made, it shall follow the procedure set forth herein 151
and shall conform to the regulations and requirements of the Unified Development 152
Ordinance. 153
2. Consultation with the Director of Community Services and Application: Applicants 154
shall meet with the Director of Community Services to review the zoning 155
classification of their site, review copies of the regulatory ordinances and materials, 156
review the Special Exception procedures, and examine the proposed exception and 157
development of the property. The Director of Community Services shall aid and 158
advise the applicant in preparing the application and supporting documents as 159
necessary. The Director of Community Services will inform the applicant that the 160
Group Home building must meet the Indiana Department of Homeland Security's 161
building classification requirements. The applicant shall then submit two (2) copies 162
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of the written application form and all necessary supporting documents and 163
materials. 164
3. Initial Review by the Director of Community Services: Docketing on Board of Zoning 165
Appeals Hearing Officer Agenda: Following the receipt of the written application 166
and necessary supporting documents and materials by the Director of Community 167
Services, the Director shall then review the materials solely for the purpose of 168
determining whether the application is complete and in technical compliance with all 169
applicable ordinances, laws, and regulations, and therefore entitled to be forwarded 170
to the Board of Zoning Appeals. If the materials submitted by the applicant are not 171
complete or do not comply with the necessary legal requirements, the Director of 172
Community Services shall inform the applicant of the deficiencies in said materials. 173
Unless and until the Director of Community Services formally accepts the Special 174
Exception application as complete and in legal compliance, it shall not be considered 175
as formally filed for the purpose of proceeding to succeeding steps toward Special 176
Exception approval as hereinafter set forth. Within thirty (30) days of the formal 177
acceptance of the application by the Director of Community Services, the Director 178
shall formally file the application by placing it upon the agenda of a the Board of 179
Zoning Appeals Hearing Officer, according to the Rules of Procedure of the Board 180
of Zoning Appeals. 181
4. Short Term Rentals Renewal Applications. Short-Term Residential and Short-Term 182
Non-Dwelling Rental renewal applications shall be docketed, filed with, and placed 183
on the agenda of the Hearing Officer for the public hearing according to the Rules 184
of Procedure of the Board of Zoning Appeals. The same rules for public hearing, 185
basis of review and approval/denial, and re-application shall apply for Short-Term 186
Residential and Short-Term Non-Dwelling Rental renewal applications as initial 187
application for Special Exception. 188
5. Public Hearing: Once the Director of Community Services has accepted and filed 189
the application with The Board of Zoning Appeals a Hearing Officer, a docket 190
number shall be assigned and a date and time set for a public hearing by The Board 191
of Zoning Appeals Hearing Officer, according to the Rules of Procedure of the Board 192
of Zoning Appeals. The applicant shall be responsible for the cost and publication 193
of any required published legal notification of the public hearing. The applicant shall 194
also notify all interested parties and property owners as required by the Rules of 195
Procedure of the Board of Zoning Appeals; however, notice by publication shall not 196
be required for the renewal of a Special Exception. The conduct of the public hearing 197
shall be in accordance with the Board of Zoning Appeals Rules of Procedure. 198
6 Approval or Denial of the Special Exception Application: Upon approval of a Special 199
Exception, the Board of Zoning Appeals Hearing Officer shall inform the applicant 200
that the applicant may apply to the Director of Community Services for 201
Improvement Location Permits (if necessary) or may commence the Special 202
Exception if no permits are required. Failure of the Hearing Officer Board of Zoning 203
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Appeals to inform the applicant of the time limits set forth in Section 5.72(D): 204
Limitations, Section 5.73(D): Limitations or Section 5.74(D): Limitations, as 205
applicable, shall not relieve the applicant of complying with said Section or 206
otherwise complying with all applicable Federal and State laws, rules, and 207
regulations. 208
7. Appeal of Hearing Officer Decision: A Short-Term Residential and Short-Term Non-209
Dwelling Rental renewal application decision of a Hearing Officer shall not be a 210
basis for judicial review, but it may be appealed to the Board of Zoning Appeals. 211
The Board of Zoning Appeals shall conduct a new hearing on the matter and shall 212
not be bound by any Findings of Fact made by the Hearing Officer. A person who 213
wishes to appeal a decision of the Hearing Officer must file the appeal with the 214
Board of Zoning Appeals within five (5) days after the decision is made, as provided 215
in I.C. 36-7-4-924. 216
8. Time Limit for Re-Application: A Special Exception application that is denied by the 217
Board of Zoning Appeals is ineligible to be placed again on an agenda for 218
consideration until the legality of the decision is finally determined by a court, 219
pursuant to judicial review according to the Advisory Planning Law, or for a period 220
of twelve (12) months following the date of the denial, whichever is later. In 221
addition, whenever a Special Exception application is denied, the property involved 222
in the application shall not be the subject of a different Special Exception 223
application, or any use variance or rezone proposal, for a period of six (6) months 224
following the date of the denial. 225
C. Basis of Review: A Hearing Officer, The Board of Zoning Appeals, in reviewing a 226
Special Exception application, shall give consideration to the particular needs and 227
circumstances of each application and shall examine the following items as they relate 228
to the proposed Special Exception: 229
1. Surrounding zoning and land use; 230
2. Access to public streets; 231
3. Driveway and curb cut locations in relation to other sites; 232
4. Parking location and arrangement; 233
5. Trash and material storage; 234
6. Necessary exterior lighting; and 235
7. Protective restrictions and/or covenants; and 236
8. Proximity and number of other Group Homes to the proposed site. 237
D. Basis of Approval or Rejection: A Hearing Officer The Board of Zoning Appeals, in 238
approving or rejecting a Special Exception application, shall base his or her its decision 239
upon the following factors as they relate to the above listed items (Section 9.08(C): 240
Basis of Review) concerning the proposed Special Exception: 241
1. The economic factors related to the proposed Special Exception, such as cost/benefit 242
to the community and its anticipated effect on surrounding property values; 243
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2. The social/neighborhood factors related to the proposed Special Exception, such as 244
compatibility with existing uses in the vicinity of the premises under consideration 245
and how the proposed Special Exception will affect neighborhood integrity; and 246
3. The effects of the proposed Special Exception on vehicular and pedestrian traffic in 247
and around the premises upon which the Special Exception is proposed. 248
E. Special Exception Group Home Decisions; Commitment: Pursuant to IC 36-7-4-1015, 249
a Hearing Officer the Board of Zoning Appeals may, as a condition to any approval of 250
an application for a Special Exception, require or allow the owner to make any or all of 251
the following commitments concerning the use of the property: 252
1. That the Special Exception will fully comply with Section 5.72 Group Home Use 253
Specific Standards. 254
2. That the Special Exception will be limited to five (5), ten (10), or fifteen (15) years, 255
at the discretion of the Board of Zoning Appeals Hearing Officer. 256
3. If the Board of Zoning Appeals Hearing Officer determines that a homeowners 257
association or similar entity has established limitations or prohibitions that apply to the 258
property, that the owner’s implementation of the Special Exception will not result in 259
the violation of any such limitations or prohibitions. 260
F. Special Exception Short-Term Residential Rental Decisions; Commitment: Pursuant to 261
IC 36-7-4-1015, a Hearing Officer the Board of Zoning Appeals may, as a condition to 262
any approval of an application for a Special Exception, require or allow the owner to 263
make any or all of the following commitments concerning the use of the property: 264
1. That the Special Exception will fully comply with Section 5.73: Short-Term Rental 265
Use-Specific Standards. 266
2. That the Special Exception will be limited to thirty (30), sixty (60), or ninety (90) 267
days during a calendar year, at the discretion of a Hearing Officer the Board of 268
Zoning Appeals. 269
3. If a Hearing Officer the Board of Zoning Appeals determines that a homeowners 270
association or similar entity has established limitations or prohibitions that apply to 271
the property, that the owner’s implementation of the Special Exception will not 272
result in the violation of any such limitations or prohibitions. 273
G: Special Exception Non-Dwelling Short-Term Rental Decisions; Commitment: Pursuant 274
to IC 36-7-4-1015, a Hearing Officer the Board of Zoning Appeals may, as a condition 275
to any approval of an application for a Special Exception, require or allow the owner to 276
make any or all of the following commitments concerning the use of the property: 277
1. That the Special Exception will fully comply with Section 5.74: Non-Dwelling 278
Short-Term Rental Use-Specific Standards. 279
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2. That the Special Exception will be limited to thirty (30), sixty (60), or ninety (90) 280
days during a calendar year, at the discretion of a Hearing Officer the Board of 281
Zoning Appeals. 282
3. If a Hearing Officer the Board of Zoning Appeals determines that a homeowners 283
association or similar entity has established limitations or prohibitions that apply to 284
the property, that the owner’s implementation of the Special Exception will not 285
result in the violation of any such limitations or prohibitions. 286
Section IV. Amend Article 11.02 Definitions as follows: 287
Home, Group: A residential Structure or facility where six (6) or more unrelated persons who 288
are in need of care, support or supervision can live together, such as children or those who are 289
elderly, disabled or mentally ill. Group Homes housing persons with developmental disabilities 290
shall obtain, comply with, and maintain a license from the Indiana Division of Disability and 291
Rehabilitative Services. Group Homes housing those living with psychiatric disorders or 292
addictions shall obtain, comply with, and maintain a license from the Indiana Division of 293
Mental Health and Addictions 294
Dwelling, Two-Family. residential Building containing two (2) Dwelling Units and not 295
occupied by more than two (2) Families. Except as otherwise provided by state statute, a Group 296
Home shall not be considered a Two-Family Dwelling and treated as such under the Unified 297
Development Ordinance. 298
299
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PASSED, by the Common Council of the City of Carmel, Indiana, this _________ day of 300
_________________, 2025, by a vote of _____ ayes and _____ nays. 301
302
COMMON COUNCIL FOR THE CITY OF CARMEL 303
304
_______________________________ ______________________________ 305
Adam Aasen, President Matthew Snyder, Vice-President 306
307
______________________________ ______________________________ 308
Jeff Worrell Teresa Ayers 309
310
______________________________ ______________________________ 311
Shannon Minnaar Ryan Locke 312
313
______________________________ ______________________________ 314
Anthony Green Rich Taylor 315
316
______________________________ 317
Dr. Anita Joshi 318
319
ATTEST: 320
321
322
______________________________ 323
Jacob Quinn, Clerk 324
325
Presented by me to the Mayor of the City of Carmel, Indiana this _________ day of 326
_________________, 2025, at _______ __.M. 327
328
329
_________________________________ 330
Jacob Quinn, Clerk 331
332
Approved by me, Mayor of the City of Carmel, Indiana this _________ day of 333
_________________, 2025, at _______ __.M. 334
335
336
_________________________________ 337
Sue Finkam, Mayor 338
ATTEST: 339
340
341
_________________________________ 342
Jacob Quinn, Clerk 343
344
Prepared by: Ted W. Nolting 345
Kroger Gardis & Regas, LLP 346
111 Monument Circle Ste. 900 347
Indianapolis, IN 46204 348
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EXHIBIT “A” 349
350
351
CERTIFICATION OF THE CARMEL PLAN COMMISSION’S RECOMMENDATION 352
ON THE PROPOSAL BY THE CARMEL COMMON COUNCIL 353
TO AMEND THE CARMEL ZONING ORDINANCE PURSUANT TO INDIANA CODE 354
§36-7-4-602(b) 355
356
ORDINANCE Z- 357
358
AN ORDINANCE OF THE COMMON COUNCIL OF THE CITY OF CARMEL, 359
INDIANA, AMENDING THE UNIFIED DEVELOPMENT ORDINANCE 360
361
To: 362
363
Dear Members: 364
365
The Carmel Advisory Plan Commission offers you the following report on the proposal by the 366
Common Council to the Commission to amend Articles 5.72, 9.08, and 11.02 of the City of 367
Carmel Unified Development Ordinance received in the form attached hereto. 368
369
The Carmel Advisory Plan Commission’s recommendation on the proposal is ______________. 370
371
At its regularly scheduled meeting on __________, 2025, the Carmel Advisory Plan Commission 372
held a public hearing after publishing notice thereof in accordance with law, and thereafter voted 373
_____ in favor, _____ opposed, _____ abstaining, to forward to the Common Council, the 374
proposed Ordinance Z- with a ____________ recommendation. 375
376
Please be advised that by virtue of the Commission’s recommendation, pursuant to IC 36-7-4- 377
607(__)(__), the Council has ninety (90) days to act on the proposal. Ninety days from the date of 378
the original certification (___________, 2025) is ______________, 2025. 379