Policy & code reform
Changing the rules that changed the neighborhood.
Missing middle housing is rarely blocked by a construction problem. It is blocked by rules: zoning that forbids the building type, codes written for larger projects, and financing boxes that small deals do not fit. We work on both sides, building the projects and reforming the rules. Malone Park Commons was our learning lab. Its lessons helped inform reforms carried by city and county planners, code officials, fellow builders, and state lawmakers: Memphis and Shelby County's 2021 Large Home Amendment, Tennessee's House Bill 2787, and the 2025 Appendix M.
Firsts under the code
Every one of these took bringing an inspector along.
Code reform at ground level looks like this: a building method that is proven elsewhere, a local code that has never seen it, and a builder willing to do the work of getting it approved. Jones Urban was the first in Shelby County to do each of the following.
- Sealed crawlspace foundations. First building firm approved by Shelby County Code Enforcement to use a sealed, conditioned crawlspace, a healthier and more efficient alternative to a vented one.
- All-electric EcoBuild homes. First to build an all-electric home meeting MLGW's EcoBuild energy-efficiency requirements.
- Ductless heat pumps for the whole house. First in Shelby County to heat and cool an entire home with ductless mini-split heat pumps.
- Electric tankless water heating. First in Shelby County to use electric tankless water heaters for whole-house hot water.
Raised floor foundations are our standard practice. Each of these is now a normal thing to do in Memphis. None of them was when we started.
The ADU story
Legal in 2011. Proven on the ground since.
The Memphis and Shelby County Unified Development Code, enacted in June 2011, legalized accessory dwelling units on single-family lots for the first time in a generation. A rule change on paper does not put a backyard cottage on a lot. Somebody has to design one that fits, get it through permitting, build it at a cost that works, and show the neighbors it is a good thing.
Jones Urban was an early builder under that provision. The cottages we built then are the reason we could build a whole block of them later, and the reason we can tell a planning commission exactly what an ADU rule does to a small project's budget and timeline.
The learning lab
Malone Park Commons showed us exactly where the code breaks.
We built one Memphis block with cottages, fourplexes, and live-work buildings, and every time a design crossed from two homes to three, it triggered rules written for large apartment buildings. We used that block as a learning lab, documented each barrier, and worked through the fixes with city and county planners, code officials, other builders, and state lawmakers.
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2021
The Large Home Amendment, Memphis and Shelby County
Effective November 1, 2021, Memphis and Shelby County amended their building code so that buildings of three to six homes are reviewed under the residential code, the same code a large house follows, instead of the commercial code. With two-hour fire-rated separations between homes, no sprinkler system is required, upper-floor homes can share an exit, and a fourplex no longer needs separate engineered drawings for every trade. The change grew out of the Memphis 3.0 comprehensive plan and was carried by the Division of Planning and Development and local code officials. We supported it from a seat on the Memphis and Shelby County Building Code Advisory Board, with Malone Park Commons as one working example.
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2024
House Bill 2787, State of Tennessee
When the State Fire Marshal objected to the local amendment, the Division of Planning and Development drafted a state bill. We worked with city staff and other home builders to advance it, including testimony before several legislative committees, and the General Assembly passed House Bill 2787 in 2024. It became law as Public Chapter 946. It lets any local government in Tennessee place three- and four-family dwellings under its residential code. For buildings under 5,000 square feet with two-hour fire separations, the state may not mandate a sprinkler system, and a lower-cost residential sprinkler standard may be allowed by local ordinance.
After the law passed, Memphis Light, Gas and Water revised its policy so buildings of up to four homes qualify for residential utility service instead of commercial taps and meters, saving thousands of dollars per home.
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2025
Appendix M, Memphis and Shelby County
In late 2025 Memphis and Shelby County adopted Appendix M, an optional code path for middle-scale housing: buildings of three to 24 homes, up to three stories. Fire protection scales with the building, from no sprinklers for small three- and four-home buildings with two-hour separations, to a residential sprinkler system for two-story buildings of up to eight homes, to a multifamily system above that. Planning and Development staff prepared the amendments, and the Building Code Advisory Board, where Andre serves, vetted and approved them before adoption.
The same approach works beyond the building code. Zoning relief, design review, brownfield cleanup, and incentive applications all got the same treatment on our projects: go through the process, write down where it costs a small building months or dollars it should not, and bring that record to the people who can change it.
Research and coverage
What others have written about the learning lab.
Planners, researchers, and writers have used Malone Park Commons to show why middle-scale housing needs more than zoning reform.
“Malone Park Commons became a master class in the invisible barriers challenging middle-scale housing development.”
John Zeanah, AICP, Chief of Development and Infrastructure, City of Memphis, National League of Cities, September 2025
- Center for Building in North America · Sept 2025Beyond Zoning: Hidden Code Barriers to Middle-Scale Housing
John Zeanah’s white paper. Malone Park Commons is its case study of the building, fire, and utility rules that stall small multifamily buildings.
- National League of Cities · Sept 30, 2025Beyond Zoning, Part 1: How Memphis Partnered with a Small Developer for Big Changes
How City of Memphis staff and local home builders worked together on local and state code changes.
- UCLA Housing Voice podcast · Nov 5, 2025Ep. 101: Beyond Zoning with John Zeanah and Andre D. Jones
Andre and John Zeanah walk through the barriers Malone Park Commons ran into and how Memphis addressed them.
- American Planning Association · Sept 16, 2025New White Paper: Creating More Housing Doesn’t End With Zoning Reform
APA’s coverage of the Beyond Zoning paper and its Memphis case study.
- Strong Towns · Oct 7, 2025When One Extra Unit Triggers a Giant Leap in Red Tape
How Memphis right-sized the code for buildings of three to six homes, with Malone Park Commons as the example.
- Opticos Design · Jan 12, 2022Memphis, TN Amends Local Building Code to Allow up to Six Units Under Residential Building Code
The first account of the 2021 amendment and the Building Code Advisory Board work behind it.
- Strong Towns · Feb 16, 2022Bringing Gentle Density to Memphis
A profile of Jones Urban, Malone Park Commons, and the code barriers still in the way.
- Community Redevelopment Agency · Mar 13, 2025Developer Andre Jones Is Creating a Bikeable City by Doing Just That, Biking
A profile of Jones Urban’s work in Uptown, including sealed crawlspaces and the state sprinkler bill.
The conversations we want to be part of
Where the rules still get in the way.
Missing middle by right
Duplexes through fourplexes and cottage courts allowed on ordinary residential lots without a rezoning or a variance.
Lot size and setbacks
Minimum lot sizes and setback rules that make a small lot unbuildable, and a small building on a normal lot illegal.
Parking minimums
Parking requirements that consume the yard a cottage court needs and add cost that a small project cannot carry.
Building code thresholds
The line between residential and commercial code that turns a three- or four-home building into a much more expensive one.
Utility and site rules
Connection, metering, and infrastructure standards sized for subdivisions, applied to one building on one lot.
Financing that fits
Lending and incentive programs that recognize a five-home building as a small deal, not a failed large one.
Bring us into the room.
Cities, planning departments, and advocacy organizations: we bring lived experience with what the code actually does to a small project. We are glad to share it.
