Bernard, Joseph A. During the Debate on 2040, There Were

Bernard, Joseph A.

From: Kaia Svien Sent: Tuesday, November 10, 2020 1:07 PM To: Wittenberg, Jason W.; Baldwin, Lisa M.; 2040; Cano, Alondra (External) Subject: [EXTERNAL] City Zoning Standards

Planning Commission Members, Staff, and Councilperson Cano,

Please take a strong stand against the proposed changes to the city zoning standards. Analysis that I‘ve read makes this sound very much like a gift to developers who most likely do not hav the vision and vlaues needed to construct housing for low income people.

I fully endorse the statement below. Please enter my submission into the Public Record.

Thank You, Kaia Svien 3632 13th Ave S, Mpls

During the debate on 2040, there were many confirmations and promises related to Built Form for Interior 1-2- 3.

Just like in the email confirmation from a Council Member, we were assured "the expectation that two- and three-family homes in low-density areas must meet the same height, setback, and massing requirements as single-family homes."

There should be NO CONSIDERATION of further movement in these areas:

1 - Approval of ADUs to be built on lots where the principal residence is non-owner-occupied. NO! This only turns over more of our NOAH properties to investors instead of local owners, making it impossible for first time homebuyers to have a shot. Investors will clamor to turn one small house or duplex into 3-4 unit property and regular residents won't be able to compete. It also stuffs more people and impervious surface on a lot and eats up greenspace.

2 - Elimination of off-street parking minimums and re-evaluation of parking maximums. NO! This is a gift to developers with the livability of our neighborhoods at risk. The ONLY place this should be a possibility is transit corridors.

3 - Shoreland Overlay Districts - These must be respected, I have seen way too many variances handed out as if there is no protection for the fragile ecosystems adjacent to our precious lakes and waterways. I want to see much stronger language propping this up, and a requirement for a public hearing each and every time there is any request to violate the SOD. 4 - Adding "premiums" to Interior neighborhoods. NO! Our neighborhoods are the jewels of our city and letting developers get premiums to make their projects more profitable, at the cost of less greenspace, more height, shadowing, more impervious surfaces, more lot coverage, more urban heat island effects is

1 unnecessary. Premiums on transit corridors is appropriate, and that provides adequate density without destroying interior neighborhoods.

5 - Current Interior 1-2-3 building envelope must be maintained as promised: - Floor Area Ratio - Setbacks - Lot Coverage - Building Height

Kaia Svien, MS Spiritual Guide, Meditation Instructor, Program Designer Mindfulness for Changing Times www.mindfulnessforchangingtimes.com [email protected] 612-722-2650 pronouns: she, hers

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2 Bernard, Joseph A.

From: steven Verdoorn Sent: Tuesday, November 10, 2020 10:17 AM To: Wittenberg, Jason W.; Baldwin, Lisa M.; 2040 Subject: [EXTERNAL] Opposed to Prroposed changes to Zoning

Dear Planning Commissioners and Council Members ‐ Please make these comments a part of the PUBLIC RECORD. During the debate on 2040, there were many confirmations and promises related to Built Form for Interior 1‐2‐3.

Just like in the email confirmation from a Council Member, we were assured "the expectation that two‐ and three‐family homes in low‐density areas must meet the same height, setback, and massing requirements as single‐family homes."

There should be NO CONSIDERATION of further movement in these areas:

1 ‐ Approval of ADUs to be built on lots where the principal residence is non‐owner‐occupied. NO! This only turns over more of our NOAH properties to investors instead of local owners, making it impossible for first time homebuyers to have a shot. Investors will clamor to turn one small house or duplex into 3‐4 unit property and regular residents won't be able to compete. It also stuffs more people and impervious surface on a lot and eats up greenspace.

2 ‐ Elimination of off‐street parking minimums and re‐evaluation of parking maximums. NO! This is a gift to developers with the livability of our neighborhoods at risk. The ONLY place this should be a possibility is transit corridors.

3 ‐ Shoreland Overlay Districts ‐ These must be respected, I have seen way too many variances handed out as if there is no protection for the fragile ecosystems adjacent to our precious lakes and waterways. I want to see much stronger language propping this up, and a requirement for a public hearing each and every time there is any request to violate the SOD. 4 ‐ Adding "premiums" to Interior neighborhoods. NO! Our neighborhoods are the jewels of our city and letting developers get premiums to make their projects more profitable, at the cost of less greenspace, more height, shadowing, more impervious surfaces, more lot coverage, more urban heat island effects is unnecessary. Premiums on transit corridors is appropriate, and that provides adequate density without destroying interior neighborhoods.

5 ‐ Current Interior 1‐2‐3 building envelope must be maintained as promised: ‐ Floor Area Ratio ‐ Setbacks ‐ Lot Coverage ‐ Building Height

Thank you,

Steven Verdoorn [EXTERNAL] This email originated from outside of the City of Minneapolis. Please exercise caution when opening links or attachments.

4 Bernard, Joseph A.

From: Jan Morse Sent: Tuesday, November 10, 2020 9:16 AM To: Wittenberg, Jason W.; Baldwin, Lisa M.; 2040; Fletcher, Steve Subject: [EXTERNAL] 2040 plan / no more concessions to developers

Greetings,

As a long‐time resident of the Marcy‐Holmes neighborhood I write to strongly object to further accommodations to developers who are looking to further damage our community while reaping greater profits.

Our community has had more than its share of tear downs and the resulting loss of architectural fabric. Formerly landscaped lots are cleared to the borders and gravel replaces grass. No trees are planted. The identical looking nondescript buildings proliferate, have the same flimsy construction, with cramped rooms and cheap finishes. Nonetheless, most of these buildings are advertised as 'luxury' apartments with many amenities and high rental costs.

The effect of these buildings has been to leave lots of the older and more affordable buildings with vacancies, who then turn to anyone they can find to rent their units. We've seen a significant increase in: ‐ traffic problems, greater number of cars moving at high speeds ‐ trash on our streets ‐ noise ‐ crime, theft from/of vehicles to car‐jackings and armed robbery

The 2040 plan has brought an overall degradation to our so‐called 'historic' community that has lost far too many interesting historic buildings, don't make it any worse than it already is.

Enough is enough.

Sincerely, Jan & Andrew Morse 518 7th St SE

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5 Bernard, Joseph A.

From: Stephanie Belseth Sent: Tuesday, November 10, 2020 6:12 AM To: Wittenberg, Jason W.; 2040; Baldwin, Lisa M.; Palmisano, Linea Subject: [EXTERNAL] Reject changes to 2040 plan

Dear Minneapolis Planning commission, council members and whomever else this may concern,

I am a 25+ year resident of southwest Minneapolis and I care very much for our amazing city and its residents.

Please make these comments a part of the PUBLIC RECORD. During the debate on 2040, there were many confirmations and promises related to Built Form for Interior 1-2-3.

We were assured "the expectation that two- and three-family homes in low-density areas must meet the same height, setback, and massing requirements as single-family homes."

MN 2040 DID go far enough, the voice of residents should NOT be ignored, and there should be absolutely NO CONSIDERATION of further movement in these areas:

6 3 - Shoreland Overlay Districts - These must be respected, I have seen way too many variances handed out as if there is no protection for the fragile ecosystems adjacent to our precious lakes and waterways. I want to see much stronger language propping this up, and a requirement for a public hearing each and every time there is any request to violate the SOD. 4 - Adding "premiums" to Interior neighborhoods. NO! Our neighborhoods are the jewels of our city and letting developers get premiums to make their projects more profitable, at the cost of less greenspace, more height, shadowing, more impervious surfaces, more lot coverage, more urban heat island effects is unnecessary. Premiums on transit corridors is appropriate, and that provides adequate density without destroying interior neighborhoods.

5 - Current Interior 1-2-3 building envelope must be maintained as promised: - Floor Area Ratio - Setbacks - Lot Coverage - Building Height

Thank you, Stephanie Belseth 4648 Vincent Ave S Minneapolis, MN 55410

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7 Bernard, Joseph A.

From: Lynette Davis Sent: Monday, November 09, 2020 11:37 PM To: 2040 Subject: [EXTERNAL] 2040 zoning

Please, please slow down and don’t ruin this beautiful city. We need our green space and as many trees as possible to alleviate global climate change. Pushing people into tighter and tighter spaces and overbuilding on already small lots is not the way! ….certainly not in the time of this pandemic and civic unrest. We all need a little space right now. We do not need developers laying waste to this city.

Keep Minneapolis beautiful AND green!

Sincerely, Lynette Davis [EXTERNAL] This email originated from outside of the City of Minneapolis. Please exercise caution when opening links or attachments.

8 Bernard, Joseph A.

From: Joey Reid Sent: Monday, November 09, 2020 8:25 PM To: 2040 Subject: [EXTERNAL] Comments on draft built form regulations

Hello,

Here are my comments on the draft built form regulations:

1. FAR maximums and building height maximums are too low, particularly in interior neighborhoods where they would prohibit attractive developments with interior courtyards that would fit well into existing neighborhoods. 2. The building height maximums in interior 2 are less than the existing buildings in many of those areas. For example, in east isles there are many apartment and condo buildings that are 3 to 3.5 stories, yet the maximum for interior 2 is 2.5. 3. Minimum lot areas are far too large, and possibly shouldn’t exist at all. Nearly everywhere I go in Minneapolis I see houses built on tiny lots that look like they used to be someone’s backyard. It don’t understand the justification for preventing this type of building, or preventing construction on existing lots that are under the relatively large “typical” lot size that is the minimum. 4. I’m suprised to see that the corridors of the existing C Line and future D Line transit routes are set to only corridor 4, and that that drops to interior two within about a block. High‐capacity, high‐frequency, high‐reliability transit service easily draws people from half a mile away, and the investment in quality service should not be squandered by limiting the ability to live near it. Everything within a quarter mile walk of an existing A, or future B, D, or E Line station should be corridor 3 to be consistent with the very definition of corridor 3, and anything between 1/4 and 1/2 mile of those stations should be interior 3, to be consistent with the defintion of interior 3! 5. It looks like many areas of the city have draft built form regulations that are more restrictive than many of the existing buildings. For example, the area around Powderhorn park has many 3 story apartment buildings, but is interior 2. This is particularly surprising as these areas are also within easy walking distance of the funded B and D Lines, and so by definition should be corridor/interior 3. 6. Minimum building heights of one story in interior 3, corridor 3, corridor 4, and two stories in corridor 6, transit 10 are not sufficient to meet the goals of the 2040 plan. These lax minimums make it far too easy to provide too little housing in the most important areas. 7. There’s not enough density allowed in most places, and for the most part, density is only allowed in loud, polluted and dangerous high‐traffic areas. This is a huge equity issue with the existing draft, as renters tend to be poorer and non‐ white relative to home‐owners. Density does not require 10 story high‐rises, but simply allowing three stories for multifamily homes and townhomes in any area with existing three‐story buildings would be sufficient. Corridor 3 should be expanded to any area within half a mile of existing high‐frequency transit. 8. The transit 10 and 15 descriptions do not at all match the locations on the map. Hennepin between Lake and Maple should all be at least transit 10, and probably better as transit 15, as it is currently served by the very‐high‐frequency route 6, as well as the 12, with additional service in parts on the 114, 115 and 17, and is crossed by the high‐frequency 2 and 21 (future B Line). The future E Line BRT will also serve the corridor, and as it is so close to downtown, and connects the region’s largest job center to one of the largest retail and entertainment centers it is exactly the description of transit 15. Same with Lyndale, Nicollet, and Chicago north of Lake Street, and Franklin between Hennepin and Hiawatha. 9. Build form regulations above transit 15 will likely only lead to further concentration downtown which tends to result in highly directional travel demand and is harder to serve with transit. Instead, built form regulations should encourage higher density neighborhood nodes throughout the city that can be efficiently served by transit, and that generate two‐ way all‐day demand.

Thank you,

Joey Reid [EXTERNAL] This email originated from outside of the City of Minneapolis. Please exercise caution when opening links or attachments.

10 Bernard, Joseph A.

From: John Speltz Sent: Monday, November 09, 2020 7:40 PM To: Wittenberg, Jason W.; Baldwin, Lisa M.; 2040 Subject: [EXTERNAL] 2040 NO NO NO

Planning Commissioners and Council Members,

Please make my comments part of the public rec0ord during the 2040 discussions. We understood that 2-family and 3-family homes would meet the same massing requirements as single-family homes. We resent that idea of hiring a “ringer” consultant to forward a re-write of the plan.

There should be NO CONSIDERATION of further movement in these areas:

 Approval of ADUs to be built on lots where the principal residence is non-owner-occupied.

 Elimination of off-street parking minimums and re-evaluation of parking maximums.

 Strict Shoreland Overlay Districts

 Adding "premiums" to Interior neighborhoods. NO

 Current Interior 1-2-3 building envelope must be maintained as promised

Thank you

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11 Bernard, Joseph A.

From: Julia Hobart Sent: Monday, November 09, 2020 5:10 PM To: 2040 Subject: [EXTERNAL] FW: Planning Commission Comment re: Built Form Regulations Attachments: Comment on Minneapolis Built Form Regulations 11.09.20.pdf

Hello,

I realized I sent this letter of comment on the Draft Built Form Regulations to the incorrect email address. Is there any way to add this comment to the public record?

Thanks, Julia

Right-click or tap and hold here to download pictures. To help protect your privacy, Outlook prevented automatic downlo picture from the Internet. Twin C ities Habitat for Humanity, 1954 Univ ersity A v e. W , St. Paul, MN 55104 Julia Hobart Policy & Advocacy Coordinator pronouns: she/her/hers

TEL/FAX 612-305-7110

Everyone deserves a safe, stable, affordable place to live. Get involved today!

The Twin Cities Habitat for Humanity office at 1954 University Ave, St. Paul, is closed to staff and public until further notice. We are serving our clients virtually and staff are continuing to build and repair homes following strict safety protocols. For the most up-to-date information, please see our COVID-19 webpage at www.tchabitat.org/coronavirus.

From: Julia Hobart Sent: Monday, November 9, 2020 10:16 AM To: [email protected] Subject: RE: Planning Commission Comment re: Built Form Regulations

Apologies. Here is a PDF copy.

TEL/FAX 612-305-7110

Everyone deserves a safe, stable, affordable place to live. Get involved today!

From: Julia Hobart Sent: Monday, November 9, 2020 10:15 AM To: [email protected] Subject: Planning Commission Comment re: Built Form Regulations

Hello,

Please find attached a written comment on the Draft Built Form Regulations, to be discussed at the Planning Commission meeting this afternoon at 4:30 PM. This comment is from several local housing developers, advocates, and partners who have signed on.

Please let me know if you have any questions.

Thank you, Julia

TEL/FAX 612-305-7110

Everyone deserves a safe, stable, affordable place to live. Get involved today!

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13 Bernard, Joseph A.

From: Mitch Karr Sent: Monday, November 09, 2020 3:26 PM To: 2040 Subject: [EXTERNAL] MSR Design, Minneapolis - Support for letter of critical changes to proposed 2040 Built- Form Regulations Attachments: Built Form Regulations comments_MSR Design.pdf

Hello,

I am writing on behalf of MSR Design and the Partners of the Firm, to express our Practice’s full and collective support of the recommendations and revisions to the proposed 2040 Plan Built‐Form Regulations contained in the attached letter.

We believe the revisions outlined in the letter are critical and would greatly improve the Built‐Form’s ability to affect and realize the sort of meaningful & livable development in our community that is the goal of the 2040 plan.

Thank you for the opportunity, and for considering this letter.

Mitch Karr, AIA Architect, Associate 612.359.3255

We enrich lives and the environment through design [EXTERNAL] This email originated from outside of the City of Minneapolis. Please exercise caution when opening links or attachments.

14 Bernard, Joseph A.

From: Melissa Licht Sent: Monday, November 09, 2020 3:00 PM To: Wittenberg, Jason W.; Baldwin, Lisa M.; 2040 Cc: Gordon, Cam A. Subject: [EXTERNAL] the 2040 plan is already bad enough, thank you!

Dear City Planning Commission Staff and Cam Gordon,

On short notice, I am not able to make the meeting this afternoon, but want to make these comments part of the PUBLIC RECORD.

During the debate on the 2040 plan, many citizens voiced opposition to the process and guidelines imposed for our city’s “development.” Much as 2040 advocates shrugged off questions about the environmental consequences of increased density and used affordable housing as a ruse claim the moral high ground and push for the plan to be passed, they are now attempting to amplify 2040’s huge rezoning consequences despite the promises made regarding Built Form in Interior 1-2-3.

I believe that while it may not fully optimize developers’ profits, the city has a responsibility to respect and protect the quality of life and sociability in its existing neighborhoods. Please uphold the provision that multi-family developments retain the same height, setback, and massing requirements as single-family homes.

Please do not add to the 2040 plan’s disruption of neighborhood livability.

1 - Do not approve of ADUs on lots where the principal residence is non-owner-occupied.

2 - Do not eliminate off-street parking minimums; maintain parking maximums.

3 - Respect Shoreland Overlay Districts.

4 - Do not add "premiums" to Interior neighborhoods. Premiums on transit corridors can provide adequate density without destroying interior neighborhoods.

5 - Maintain current Interior 1-2-3 building envelope zoning: - Floor Area Ratio - Setbacks - Lot Coverage - Building Height

Thank you,

15 Melissa Licht Ward 2

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16 Bernard, Joseph A.

From: Mike Welna Sent: Monday, November 09, 2020 2:58 PM To: Wittenberg, Jason W.; Baldwin, Lisa M.; 2040 Subject: [EXTERNAL]

Dear Planning Commissioners and Council Members - Please make these comments a part of the PUBLIC RECORD. During the debate on 2040, there were many confirmations and promises related to Built Form for Interior 1-2- 3.

There should be NO CONSIDERATION of further movement in these areas:

5 - Current Interior 1-2-3 building envelope must be maintained as promised: - Floor Area Ratio - Setbacks - Lot Coverage - Building Height

Thank you,

Michael Welna Ward 13 Resident

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18 Bernard, Joseph A.

From: Mary Pattock Sent: Monday, November 09, 2020 2:28 PM To: Wittenberg, Jason W.; Baldwin, Lisa M.; 2040; Lisa Goodman Cc: Evan Carlson; Dave Ruebeck and Claire; CIDNA Neighborhood Subject: [EXTERNAL] Proposed changes to Mpls 2040 Regulations

On behalf of the Cedar-Isles-Dean Neighborhood Association, I write opposing the proposals to increase density and eliminate development restrictions that are currently in place under 2040, including those targeting Interior 1, 2 and 3 residential neighborhoods.

We address you from these principles:

 Minneapolis should maintain a variety of neighborhood and housing options, including single family housing, which is attractive to large families and families with children (that includes immigrant families);  The proposals would further erode the environment and invite "urban heat island" effects. If environmentalism is a goal of Mpls 2040, then we should not be destroying trees and greenspace, lakes and rivers by relaxing the code. Trees, lakes and greenspaces are the environment — precisely what we are trying to protect. (The proposals are reminiscent of "We had to destroy the village in order to save it.")  It would be dishonest and an abuse of process to change, at this time — after the fact — fundamental concepts of Mpls 2040 as drafted.

Here is what we request: 1. More restrictive rules governing development in higher density areas (such as Corridor 6) that are immediately adjacent to lower density areas (such as Interior 1) without any density transitions,in order to not negatively impact or harm existing properties. 2. Clarifying language to confirm continued exclusion of accessory building, including detached garages, from the FAR calculation. 3. Prohibiting new construction from interfering with the operation of existing solar panels, in order to decrease fossil fuel consumption and preserve the integrity of existing homes. 4. A schedule of specific metrics and actions to achieve the current goal of 40 percent citywide tree canopy — with a specific deadline, perhaps the end of 2030, and to maintain the canopy at that level thereafter, in order to aggressively reduce Urban Heat Island effect. Measures may include, for example, considering a tree shading a dwelling as a “premium,” and implementing a one-for-one tree replacement requirement. 5. Elimination of references to building (6 stories) on parklands as this is incompatible with the MPRB mission. 6. Clarification on proposed changes to ADUs: Iss accessory building included in the FAR? Can a triplex have an ADU under new proposal? If so, is the ADU subject to commercial building code? If so, does ADU trigger ADA compliance regs? 7. Preservation of set backs and lot coverage ratio 8. No subdivision of existing parcels in Interior 1and 2 9. No approval of ADUs to be built on lots where the principal residence is non-owner-occupied. This only turns over more of our NOAH properties to investors instead of local owners, making it impossible for first time homebuyers to have a shot. Investors will clamor to turn one small house or duplex into 3-4 unit property and regular residents won't be able to compete. It also stuffs more people and impervious surface on a lot and eats up greenspace. 2 - Elimination of off-street parking minimums and re-evaluation of parking maximums. NO! This is a gift to developers with the livability of our neighborhoods at risk. The ONLY place this should be a possibility is transit corridors. 3 - Respect for Shoreland Overlay Districts, Too many variances are handed out as if there is no protection for 19 the fragile ecosystems adjacent to our precious lakes and waterways. Instead, we need much stronger language propping protecting our lake and river areas, and a requirement for a public hearing every time there is any request to violate the SOD. 4 - No"premiums" in Interior neighborhoods. Our neighborhoods are the jewels of our city and letting developers get premiums to make their projects more profitable, at the cost of less greenspace, more height, shadowing, more impervious surfaces, more lot coverage, more urban heat island effects is unnecessary. Premiums on transit corridors is appropriate, and that provides adequate density without destroying interior neighborhoods. 5 - Preservation, as promised, of current Interior 1-2-3 building envelope : - Floor Area Ratio - Setbacks - Lot Coverage - Building Height

Thank you for your consideration.

Mary Pattock, Chair Cedar-Isles-Dean Neighborhood Association

612-922-7609

"Be kind. Be useful. Be fearless." ~ Barack Obama

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20 Bernard, Joseph A.

From: hhanka Sent: Monday, November 09, 2020 2:18 PM To: 2040 Subject: [EXTERNAL] sy no to the special interest groups on the 2040 plan

There should be NO CONSIDERATION of further movement in these areas: Leave our Beautiful city alone. Holly Hanka

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21 Bernard, Joseph A.

From: Eric Daigre Sent: Monday, November 09, 2020 2:11 PM To: Wittenberg, Jason W.; Baldwin, Lisa M.; 2040 Cc: Gordon, Cam A. Subject: [EXTERNAL] comment re. public hearing today 9/11 4:30 pm

Dear Planning Commissioners,

Please make these comments part of the public record.

As you put the zoning code together for the 2040 plan, I am opposed to further increasing density and eliminating development restrictions (increasing building heights, reducing setbacks, eliminating minimum lot sizes, and increasing buildable areas on lots) beyond what is already in place in the 2040 plan, as I understand you're being pressured to do.

We were told that the 2040 plan's expectation is that "two and three family homes in low‐density areas must meet the same height, setback, and massing requirements as single‐family homes" (Council Member Jeremy Schroeder).

The council and mayor already passed the 2040 plan in spite of overwhelming evidence‐based criticism; a 2040 plan that further disrespects green space, staves off environmental reviews, and enriches developers under the guise of "affordable housing" erodes what little trust remains and further divides the electorate.

Sincerely,

Eric Daigre Ward 2

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22 Bernard, Joseph A.

From: Sarah Berke Sent: Monday, November 09, 2020 2:09 PM To: 2040 Subject: [EXTERNAL] Comments-Built Form Rezoning Study Attachments: FHFund Letter - Built form Mpls 2020 Nov 9.pdf

Dear Planning Commission, See attached comments from Family Housing Fund re: Built Form Rezoning Study proposals. Thank you, Sarah

Sarah Berke Program Officer FAMILY HOUSING FUND 310 4th Avenue South | Suite 9000 | Minneapolis, MN 55415 T 612.274.7690 E [email protected]

The Family Housing Fund is a nonprofit intermediary organization whose mission is to help the affordable housing network adapt to the needs of families in complex and constantly changing conditions.

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23 Kurt M. Anderson 4618 Pillsbury Avenue South Minneapolis, Minnesota 55419-5516 (612) 825-1303

November 4, 2020 Via e-mail and delivery

Minneapolis City Planning Commission c/o Planning Department staff 250 S 4th St Unit 300 Minneapolis, MN 55415

Re: Comments on Minneapolis 2040

Dear Madam or Sir:

I am enclosing 12 copies of comments on Minneapolis 2040, ten for the Commission members and two extra for you to file or dispose of as you deem proper. Please distribute them to the Commission members. Thank you. ~./4?---- KURT M. ANDERSON

KMA/ Enclosures Kurt M. Anderson 4618 Pillsbury Avenue South Minneapolis, Minnesota 55419-5516 (612) 825-1303

Via e-mail and delivery

Memorandum To: Minneapolis City Planning Commission From: Kurt M. Anderson ciJAA/l · Date: November 4, 2020 T/ f 11rcr-- Re: Comments on Minneapolis 2040

These are my comments, as the Commission solicits them through the city's Built Form-Study web page. In composing them, I am aware that many will take a narrow view of the task before the Commission, seeking to limit the issues to technical questions regarding building regulations. I am uncertain what types of financial or ideological interests may underly those constraints. But it would take an impressive set of blinders to deny that since the City Council's last major action on the 2040 plan the world in general, and Minneapolis as an epicenter of social disharmony, has changed drastically. In addition to worldwide racial tension sparked by an event in this city, the COVID-19 pandemic has been, the Economist magazine stated it, a "black swan" that has "upended everything."1 It is up to the Commission and the Council to counter the planning inertia in order to respond to those changes.

Role of the Planning Commission. Under the city charter, the Commission is mandated to "prepare ~ comprehensive plan for the City's physical development and improvement, with particular regard to public utility and convenience and the general welfare." Charter Art. VII § 7.2(e)(2)(a). This includes an obligation to monitor and propose modifications to the plan as circumstances require.

Goals and misdirected policies. My comments review the proposed zoning changes under the 2040 plan against the stated goals of the plan that are most relevant to zoning. To a large extent, the stated goals provide an empty background of lip service while the substance of the zoning changes is a dream sphere of opportunity for large scale residential developers, absentee landlords, and similar interests. It also promises at least 20 years of uncertainty for individual homeowners and resulting blight, as all kinds·ofhome updates and major maintenance tasks go on hold.

These comments also recall some of the reported statements of councilmembers in the earlier stages of the 2040 process. The statements reflect aspirations that have gone down the drain in favor of finalizing any kind of plan:

Economist, "The Peril and the Promise" (October 8, 2020), limited availability at https:/lwww.economist.com/special-report/2020/10/08/the-peril-and-the-promise.

Minneapolis 2040 Comments Kurt M. Anderson November 4, 2020 Pagel

Bender said she would only support the final plan if it’s accompanied by an inclusionary zoning ordinance — a rule that would require large-scale developers to include affordable units in otherwise market-rate projects. Schroeder also said he believes some type of mechanism to encourage below-market-rate housing will be a necessary companion for the plan to succeed. …

[Schroeder] worries the current plan would allow for “inorganic growth.” He said he doesn’t want to see a six-story apartment building erected next to a single-family home.

Schroeder has also heard the concerns that the plan will attract private developers who will take advantage of the new zoning codes without deference to the character or wishes of the neighborhood.

“I think that is a real concern, to make sure we’re holding developers accountable to the city’s goals,” he said. “And frankly the plan doesn’t have that yet.”

Council Member Andrew Johnson … said he also has concerns that the draft plan allows for large structures in the wrong places.2

In its current form, the plan does little to address these concerns, amounting instead to a general sellout to developers. Minneapolis planning staff candidly consign the equity issue to the bureaucratic Siberia of “programmatic” (as opposed to zoning) considerations.3

Importance of promoting home ownership. An underlying theme in my comments is the value of home ownership. “‘Owning the land is what gives people stability in their lives, to build community and to build wealth,’ said Kirsten Delegard, a public historian and director of Mapping Prejudice … .”4 This is not a new observation. It was also expressed in the now-quaint language of 1880, in the Minnesota Supreme Court’s comments on the protection of homesteads:

The law originated in the wise and humane policy of securing to the citizen against all the misfortunes and uncertainties of life the benefits of a home not in the interest of himself, or, if a married man, of himself and family alone, but likewise in the interest of the state, whose welfare and prosperity so largely depend upon the growth and cultivation among its citizens

2 StarTribune, “Feeling the heat, Minneapolis council members say 2040 plan must change” (July 21, 2018), https://www.startribune.com/feeling-the-heat-minneapolis-council-members-say-2040-plan-must- change/488810061/ .

3 September 23, 2020 online open house: draft built form regulations, at 42:30 et seq., video replay available at https://www.youtube.com/watch?v=v3YsLmuLBKo&feature=youtu.be.

4 StarTribune, “Curious Minnesota - How did Minn. become one of the most racially inequitable states?” (September 6, 2019), www.startribune.com/how-did-minnesota-become-one-of-the-most-racially-inequitable- states/547537761/?om_rid=1607116233&om_mid=417540553.

Minneapolis 2040 Comments Kurt M. Anderson November 4, 2020 Page 2

of feelings of personal independence, together with love of country and kindred—sentiments that find their deepest root and best nourishment where the home life is spent and enjoyed.5

Home ownership is also, by far, the most certain defense against gentrification.

We need to refocus our efforts. Recognizing that the world itself has experienced a reset, the housing policy should be reset with a laser focus on the following points:

1. Fulfilling the affordable housing “need” (quota), disproportionate as it is,6 imposed on the city by the Metropolitan Council.

2. Matching home ownership opportunities to disadvantaged persons, with priority to persons whose ancestors lived within Minneapolis boundaries and experienced discrimination, for example from covenants, redlining, and general prejudice.

3. Requiring owner-occupancy of at least one unit of any duplex or triplex built within traditional single-family neighborhoods. Removing the unrelated persons restriction also was a helpful initiative; but the goal of equitable home ownership will be promoted only if that change is tied to owner occupancy. Neighbors should not have to call landlords in distant places when neighborhood issues arise.

These focused efforts require us to abandon zoning proposals that mark homes for slow destruction, in the 21+ square mile residential area between 38th Street on the south, and Lowry Avenue on the north, and also along transit corridors outside of that area – in all, approaching half of the residential area of the city. Instead, preserve those homes and encourage economical forms of home ownership. Allow denser development to grow, as one councilmember expressed it, organically – emanating from historically commercial and denser residential nodes (points, not corridors), into parts of the city where higher density development enjoys neighborhood support and harmonizes with the character of the neighborhood.

5 Ferguson v. Kumler, 27 Minn. 156, 159, 6 N.W. 618, 619 (1880), https://cite.case.law/minn/27/156/.

6 Comparing Minneapolis with the next two largest cities in the metro area:

City 2019 Population Affordable Quota as % of Total housing Quota as % of estimate housing quota population units housing units Bloomington 90,271 586 0.649% 39,442 1.49% Minneapolis 435,885 4499 1.032% 192,791 2.33% St. Paul 315,925 1973 0.625% 124,805 1.58%

Sources: https://metrocouncil.org/Housing/Planning/Affordable-Housing-Measures/Existing-Housing-Assessment- Summary-File-(October.aspx https://metrocouncil.org/Housing/Publications-And-Resources/HOUSING-POLICY-PLANS-REPORTS/2011- 2030-Allocation-of-Affordable-Housing-Need.aspx https://metrocouncil.org/Data-and-Maps/Publications-And-Resources/Files-and-reports/2019-Population- Estimates-(FINAL,-July-2020).aspx.

Minneapolis 2040 Comments Kurt M. Anderson November 4, 2020 Page 3

The Stated Goals of Minneapolis 2040

Goal 1. Eliminate disparities In 2040, Minneapolis will see all communities fully thrive regardless of race, ethnicity, gender, country of origin, religion, or zip code having eliminated deep-rooted disparities in wealth, opportunity, housing, safety, and health.

A new policy that encourages rental over home ownership is an investor’s bonanza and leads to gentrification. If the major west coast cities are any indicator, we will not be able to build our way out of accelerating prices and rents. Instead, we need to take measures to (1) increase the rate of home ownership among persons subject to historical discrimination, and assure that ownership diversifies all neighborhoods in the city; and (2) as new rental units are built, impose very aggressive requirements for affordable units, effectively requiring owners and market rate tenants to subsidize the affordable units. At 20 units, the threshold for these requirements is too high. At 20 years, duration of these requirements is too short. 7 The requirements should begin with the first unit, while considering multiple projects from the same developer group in calculating compliance with the affordable housing ratio. The duration should be indefinite.

We also need to recognize that many renters are aspiring homeowners, and look for ways to enable them to either purchase homes, or to acquire equity interests in their rental properties. 8 Failure to do that now will increase future disparities, as renters approach the end of their productive years and still face large housing costs. “Like millions of other Americans, my home is now my primary source of wealth. It’s my hope for retirement and my backup plan for financing my children’s college education. Eight years after I bought it, my mortgage payments are lower than what many of my friends and colleagues pay to rent their apartments.”9

Planning for the destruction of a large portion of existing Minneapolis housing (I estimate 2,500 homes in Corridor 3 and Interior 2 alone, before even entering the 38th to Lowry zone of destruction) is a travesty. A possible reason for the disconnect between aspirations to equity and any reasonable policy directed to that end, may be the great rhetorical leap between restrictive covenants that went away a lifetime ago, and a desire to do something, anything, to expiate a sense of collective guilt. While that history justifies intervention on behalf of historically disfavored groups, the intervention must address the social problems we face today. That

7 StarTribune, “Affordable units now a requirement for new apartment buildings in Minneapolis” (December 13, 2019), https://www.startribune.com/affordable-units-now-a-requirement-for-new-apartment-buildings-in- minneapolis/566178991/.

8 In this regard, it is particularly frustrating to recall the missed opportunity occasioned by the housing recession of 2007-09. Instead of capturing or preserving homeownership opportunities for disadvantaged persons, foreclosures resulted in a major transfer of opportunity and wealth to investors. E.g. Marketplace.org, “Who benefited from America’s housing bust?” (November 15, 2019), https://www.marketplace.org/2019/11/15/who-benefited-from-americas-housing-bust/.

9 Marketplace.org, “Who benefited,” note 8 above.

Minneapolis 2040 Comments Kurt M. Anderson November 4, 2020 Page 4

something begins with a push to increase home ownership and thereby to promote the deep, long term psychological investment of our residents in their neighborhoods.

Goal 2. More residents and jobs In 2040, Minneapolis will have more residents and jobs, and all people will equitably benefit from that growth.

After decades of decline, Minneapolis proper has enjoyed a resurgence of population growth. It is uncertain how the COVID-19 pandemic will affect that growth curve – including whether a decline in the use of downtown commercial space will make more properties available for residential development. The growth has been fueled by luxury and market rate properties built on the downtown periphery and in downtown itself.10 Belatedly, policy makers have noticed the resulting disparities and have decided that traditional neighborhoods need to pay the price for correcting them. Instead, the disruption should occur in these new developments, with affordable housing requirements – retroactively imposed, if necessary. The practice of allowing large economic interests to purchase exemptions from this common cause, reminiscent of Civil War conscription practices, needs to cease.

Furthermore, Minneapolis should reject playing the role of Manhattan to St. Paul’s and the suburbs’ outer boroughs. Our interstate highways are not 45 mph no-truck boulevards, and our airport approaches are not occasional substitutes for the main traffic. In these respects, plus our commercial core, plus having a population density eight times the metro area as a whole,11 we already make a huge contribution to the metro area. Our city is not the next metro candidate for additional density.

Goal 3. Affordable and accessible housing In 2040, all Minneapolis residents will be able to afford and access quality housing throughout the city.

As I previously asserted, the new triplex and unrelated occupant changes are potentially helpful in opening opportunities for affordable home ownership. But commentary on the 2040 plan fairly questions whether the broader zoning changes will reduce housing costs. It notes the cost

10 E.g., StarTribune, “Almost 50,000 people now calling downtown Minneapolis home” (February 14, 2019), https://www.startribune.com/almost-50-000-people-now-calling-downtown-minneapolis-home/505811772/; Minneapolis Downtown Council, “Key Facts,” https://www.mplsdowntown.com/facts/.

11 The seven-county metro area has a population of 3,114,035, occupying 2,974 sq. mi., for a density of 1,047 persons per sq. mi. https://en.wikipedia.org/wiki/Minneapolis%E2%80%93Saint_Paul. Minneapolis has a population density of 8,094 persons per sq. mi. https://worldpopulationreview.com/us-cities/minneapolis-mn- population. St. Paul’s is 6,001. https://worldpopulationreview.com/us-cities/st-paul-mn-population.

Minneapolis 2040 Comments Kurt M. Anderson November 4, 2020 Page 5

of producing new housing units, and the likelihood that the 2040 bonanza will result in a bidding war for bulldozable properties.12

Indeed, a recent study in Auckland, New Zealand revealed that upzoning actually increases the cost of housing as existing lots are repriced according to their new development value. Following these results, Minneapolis’ single-family lots with older, smaller homes will see noticeable price increases as developers compete for initial triplex pads.13

One may also surmise that prices are set at the margins; therefore, unless we can achieve supply that overwhelms demand, prices will continue to rise.

***

Goal 6. High-quality physical environment In 2040, Minneapolis will enjoy a high-quality and distinctive physical environment in all parts of the city.

Good idea. Don’t mess up the high quality and distinctive physical environment that has already brought us decades of worldwide renown.

Goal 7. History and culture In 2040, the physical attributes of Minneapolis will reflect the city’s history and cultures.

Marking a near-majority of Minneapolis homes for destruction denigrates rather than reflects the city’s history, and honors no culture. The 2040 plan reflects Minneapolis’s history and cultures in the way that Robert Moses reflected those of The Bronx, and faintly resembles the Curtis LeMay approach to modernizing cities.

12 E.g., MinnPost, “How much will Minneapolis’ 2040 plan actually help with housing affordability in the city?” (May 31, 2019), https://www.minnpost.com/metro/2019/05/how-much-will-minneapolis-2040-plan-actually- help-with-housing-affordability-in-the-city/; J. Filstrand, “Will Minneapolis 2040 Live Up to its Promise?” (October 2, 2020, advocating for more aggressive changes and followed by extensive comments), https://streets.mn/2020/10/02/will-minneapolis- 2040-live-up-to-its-promise/.

13 S. Katkov and J. Schoenwetter, “Minneapolis’s Great Experiment” (MSBA Bench and Bar March 2020), https://www.mnbar.org/archive/msba-news/2020/03/02/minneapolis-s-great-experiment-an-introduction-to- the-minneapolis-2040-comprehensive-plan (subscription required). The authors footnote to Ryan Greenway- McGrevy, Gail Pacheco & Kade Sorenson, “Land Use Regulation, the Redevelopment Premium and House Prices, 2” (Univ. of Auckland: Economics Working Paper Series, Sept. 2018). https://www.aut.ac.nz/__data/assets/pdf_file/0003/163542/AUT_wp_2018_02_updated.pdf.

Minneapolis 2040 Comments Kurt M. Anderson November 4, 2020 Page 6

***

Goal 9. Complete neighborhoods In 2040, all Minneapolis residents will have access to employment, retail services, healthy food, parks, and other daily needs via walking, biking, and public transit.

And all of that, unimpeded by the practical needs in raising families. Complete lack of consideration for automobiles under Goal 9 promises dramatically incomplete neighborhoods. I happen to be a transit and bicycle user in my business, but our Prius is indispensable. Affordable food depends on large box co-ops and commercial grocers and often involves large orders. The neighborhood grocers that I remember from my school days in New York, assuming they still exist there, are not likely to be replicated here. The small Minneapolis medical clinic that once existed a mile south of me now may be viewed, in a wall photograph, in the Southdale Medical Center building. Sick people cannot get to doctors on their skateboards.

One commenter wonders whether the public schools (and for that matter, all schools) have been “ghosted” by the plan:

The emphasis seems to be more on turning Minneapolis into a “city without children,” in the words of writer Benjamin Schwarz. (He attributes this push to a “bevy of trend-conscious city planners, opportunistic real-estate developers, municipal officials eager to grow their cities’ tax bases, and entrepreneurial urban gurus that ballyhoo the national renaissance of what inevitably gets described as the Vibrant Urban Neighborhood.”)14

Goal 10. Climate change resilience In 2040, Minneapolis will be resilient to the effects of climate change and diminishing natural resources, and will be on track to achieve an 80% reduction in greenhouse gas emissions by 2050.

Present throughout the 2040 discussion is the acronym NOAH (naturally occurring affordable housing). I propose another one, closely related – NOCR (naturally occurring citizen responsibility). In addition to voting with their feet in favor of diverse engagement, individual homeowners in Minneapolis have balanced their practical family and living needs – which could have propelled them to the suburbs or exurbs – with big picture questions such as the environmental impact of long commutes, the cost of heating and maintaining oversized spaces, and the general inefficiency of life on the rim rather than near the hub of the metro wheel. They have done so without the heavy-handed guidance of urban planners. Eliminating single family

14 Bright Light Small City, “Minneapolis Public Schools ‘Ghosted’ by 2040 City Plan” (May 29, 2018), https://www.brightlightsmallcity.com/minneapolis-public-schools-ghosted-by-2040-city-plan/, citing to Schwartz, “Cities Without Children” (The American Conservative, June 6, 2016), https://www.theamericanconservative.com/articles/cities-without-children/.

Minneapolis 2040 Comments Kurt M. Anderson November 4, 2020 Page 7

residences in large parts of Minneapolis merely moves that culture to more remote locations, forcing those bad choices, where it will have precisely the harmful impact that 2040 aspires to avoid. 2040 cannot box out those consequences at the city limits.

***

Goal 14. Equitable civic participation system In 2040, Minneapolis will have an equitable civic participation system that enfranchises everyone, recognizes the core and vital service neighborhood organizations provide to the City of Minneapolis, and builds people’s long term capacity to organize to improve their lives and neighborhoods.

Under Goal 14, in addition to a familiar-appearing list of “people with disabilities, people of color, indigenous people and others who have been historically underrepresented in civic life,” the list of the underrepresented includes renters.15 One would not have to look far to identify renters who are active in Minneapolis’s civic life. But the 2040 authors acknowledge the underlying concern expressed in my comments, and in the quote from Ms. Delegard – that renters tend not to immerse themselves to the same extent as homeowners in activities affecting their immediate neighborhoods, or in weaving themselves into the neighborhood social fabric (if the 2040 authors intended something else in identifying this challenge, I will leave it to them to explain it). Homeownership builds community by focusing people on long-term concerns regarding their immediate surroundings.

15 Minneapolis 2040 Goal 14, https://minneapolis2040.com/goals/equitable-civic-participation-system/.

Minneapolis 2040 Comments Kurt M. Anderson November 4, 2020 Page 8

5 November 2020

Planning Commission City of Minneapolis

Re: Comment on the Draft Built Form Zoning Regulations

Dear Members of the Minneapolis City Planning Commission:

The Minneapolis 2040 Plan presents a broad vision for a changing and growing Minneapolis. The plan focuses on advancing environmental and racial justice through a variety of strategies, including by increasing housing density in our City. The 2040 Plan declares an intent to “undo the legacy that remains from racially discriminatory housing policies by increasing access to opportunity through a greater diversity of housing types, especially in areas that lack housing options as a result of discriminatory housing policy.” 4 However, we do not think the Draft Built Form Regulations live up to this stated goal. There are several regulations we believe fall short of the 2040 Plan’s vision for our City. Here is our analysis on why these regulations fall short and how they could be improved.

First, the proposed floor area ratios (FAR) place a significant limit on density in residential zones.2 The Minneapolis 2040 Plan was lauded for putting an end to single-family zoning by allowing the development of duplexes and triplexes on single-family lots. However, the proposed FAR do not demonstrate the stated vision for increased density. The Draft Built Form Regulations limit the floor area ratio to 0.5 for residential lots with 1-3 units in Interior 1 and Interior 2 Districts. For a single-family dwelling, a FAR of 0.5 seems reasonable. But, for the development of duplexes and triplexes, this regulation would curb unit size, functionally capping units at one or two bedrooms. This will have the unintended consequence of making new development less family-friendly and less dense.

Instead, we recommend increasing the maximum FAR for duplexes and triplexes and tiering FAR based on the number of proposed units. This will allow new development to meet the needs of a variety of households and household sizes. See our specific FAR recommendations in the table below. These numbers are based on the understanding that Interior 1 lots tend to be larger, commonly up to 6250 square feet, while Interior 2 lots tend to be slightly smaller, around 4800 sq. ft., and Interior 3 lots tend to be even smaller.

District Base Zone Allowed FAR (Draft Built Form) Allowed FAR (Recommendation) Interior 1 R, OR 0.5 for 1-3 units 0.5 for 1 unit, 0.55 for 2 units, 0.6 for 3 units Interior 2 R, OR 0.5 for 1-3 units, 0.8 for 4+ units 0.5 for 1 unit, 0.65 for 2 units, 0.8 for 3+ units Interior 3 R, OR 0.5 for 1 unit, 0.6 for 2 units, 0.7 for 3 0.5 for 1 unit, 0.7 for 2 units, 0.9 for 3 units, units, 1.4 for 4+ units 1.4 for 4+ units

A maximum FAR of 0.5 for Interior Districts 1-2 actually preserves the “legacy of racially discriminatory housing polices,” by limiting development that meets the needs of low- and moderate-income people, as well as large or non-nuclear family structures. To render the bold ideas of the 2040 Plan, both the Built Form Map and the Built Form Regulations must avoid placing unnecessary limitations on density. An increased and varied supply of housing is necessary for Minneapolis to create an environment where all communities—and households—can thrive.3

Second, the proposed minimum lot size further limits the possibility of increased density. The Draft Built Form suggests maintaining the existing standards for minimum lot size—lot sizes must be at least 5000 or 6000 sq. ft. for most Built Forms, including Interiors 1-3. These minimums limit density in neighborhoods that are largely residential, less dense, and therefore prime options for added infill development. A significant portion of the City’s existing housing stock, over 14,000 buildings in Interior Districts 1-3, is built on lots smaller than the proposed minimums.4 There are small lots that have gone undeveloped, in part because of lot size minimums. And large lots cannot be subdivided into parcels smaller than the minimum, which further limits options for development.

510 Marquette Avenue South, Suite 200 Minneapolis, MN 55402 | 612.375.0336 msrdesign.com However, smaller lots can sustain smaller buildings and unit sizes. Lowering minimum lot sizes could allow for expanded creativity and nimbleness in development and increase the variety of housing options. At a time when we need to be developing more affordable units, we shouldn’t overlook the option of developing smaller buildings on smaller lots. For these reasons, we propose eliminating the minimum lot size for previously developed lots and setting a lot size minimum of 3500 sq. ft. for undeveloped lots.

Third, the affordability incentives as drafted fail to support affordability in a meaningful way, and instead further the racially inequitable impacts of exclusionary zoning. The Built Form incentives reward developments that exceed ordinance requirements—in features such as parking, affordability, or sustainability—with an increased FAR value. None of the proposed incentives are applicable for developments in Interior Districts 1-2. Moreover, the affordability incentive only kicks in for developments of 20 units or more. By reserving affordability premiums only for Districts with greater density, the Draft Built Form Regulations will further concentrate affordable housing in denser areas of the City. This preempts efforts to integrate affordable housing options into neighborhoods that formerly allowed only single-family homes. By limiting affordable development to denser areas, this incentive fails to promote mixed income communities throughout the city and would solidify the impacts of exclusionary zoning.

We propose revising the affordability incentive in the following ways. First, the affordability incentive should be extended to apply to developments in Interior Districts 1-2. Second, the incentive should apply to any Interior 1 project with 3+ units, and any Interior 2 project with 4-6 units. This means the City’s inclusionary zoning requirements would not apply, as they are specific to buildings of 20 or more units. As an alternative, we suggest that for developments of 3+ units in Interior 1 Districts, the inclusion of one unit affordable at 60% AMI would allow permission to add an additional, fourth unit, with a FAR increase of 0.2, to 0.8. For developments of 4-6 units in Interior 2 Districts, the inclusion of two units affordable at 60% AMI would allow permission to add 3 additional units per lot, as well as a FAR increase to 1.0-1.25. For developments of 10-20 units in Interior 3 Districts, the inclusion of three units affordable at 60% AMI would allow permission to add an additional floor. For Interior 3 developments of 20+ units, we suggest applying the City’s current inclusionary zoning standards, also to add an additional floor. See the table below. With these modifications, affordable housing options can be more easily integrated into lower-density neighborhoods. This will meaningfully incentivize the development of units that are affordable to a variety of households and meet a variety of household needs and preferences. These changes would promote mixed income communities and preclude the overt concentration of either wealth or poverty, which as we know, has significant implications for racial equity in our City.

Built Form District Affordability Standards Value of Premium Interior 1 (with 3+ At least one unit at 60% AMI Permission to add a fourth unit units) (FAR increases to 0.8) Interior 2 (with 4-6 At least two units at 60% AMI Permission to add 3 additional units) units per lot (FAR increases to 1.0-1.25) Interior 3 (with 10-20 units, - For 10-20 units, at least three units at 60% AMI Permission to add an additional or 20+ units) - For 20+ units, inclusionary zoning standards apply floor

Finally, increased density does not necessarily mean increased affordability. Without a strong mechanism for affordability, pro-density zoning measures can lead to a surge in the development of market-rate or luxury housing. This does not address the needs of City residents. The Minnesota Housing Partnership reports that average housing costs for properties built since 2010 are 40% higher than housing costs for other properties.5 Much of the new construction occurred in denser areas of the City. This suggests an increase in expensive housing in denser urban areas. There is a growing need for more affordable housing and for housing options in other parts of our City. Whether the Built Form Regulations truly meet the needs of Minneapolis residents depends on this affordability mechanism. We strongly urge City leaders to extend affordability incentives to smaller developments in Interior Districts 1-2.

4 https://streets.mn/2020/10/29/get-rid-of-minimum-lot-size-requirements/ 5 https://www.mhponline.org/images/stories/docs/research/NOAH-MPLS-final.pdf

Thank you for the opportunity to comment on the Draft Built Form Regulations.

Sincerely,

Traci Lesneski Paul Mellblom Matt Kruntorad Dagmara Larsen CEO/Principal Principal Principal Principal MSR Design MSR Design MSR Design MSR Design

November 9, 2020

Planning Commission City of Minneapolis

Re: Comment on the Draft Built Form Zoning Regulations

Dear Members of the Minneapolis City Planning Commission:

The Minneapolis 2040 Plan presents a broad vision for a changing and growing Minneapolis. The plan focuses on advancing environmental and racial justice through a variety of strategies, including by increasing housing density in our City. The 2040 Plan declares an intent to “undo the legacy that remains from racially discriminatory housing policies by increasing access to opportunity through a greater diversity of housing types, especially in areas that lack housing options as a result of discriminatory housing policy.”1 However, we do not think the Draft Built Form Regulations live up to this stated goal. There are several regulations we believe fall short of the 2040 Plan’s vision for our City. Here is our analysis on why these regulations fall short and how they could be improved.

First, the proposed floor area ratios (FAR) place a significant limit on density in residential zones.2 The Minneapolis 2040 Plan was lauded for putting a so-called “end” to single-family zoning by allowing the development of duplexes and triplexes on single-family lots. However, the proposed FAR are a far cry from a vision for increased density. The Draft Built Form Regulations limit the floor area ratio to 0.5 for residential lots with 1-3 units in Interior 1 and Interior 2 Districts. For a single-family dwelling, a FAR of 0.5 seems reasonable. But, for the development of duplexes and triplexes, this regulation would curb unit size, functionally capping units at one or two bedrooms. This will have the unintended consequence of making new development less family-friendly and less dense.

District Base Zone Allowed FAR (Draft Built Form) Allowed FAR (MHH Recommendation) Interior 1 R, OR 0.5 for 1-3 units 0.5 for 1 unit, 0.55 for 2 units, 0.6 for 3 units Interior 2 R, OR 0.5 for 1-3 units, 0.8 for 4+ units 0.5 for 1 unit, 0.65 for 2 units, 0.8 for 3+ units Interior 3 R, OR 0.5 for 1 unit, 0.6 for 2 units, 0.7 for 3 0.5 for 1 unit, 0.7 for 2 units, 0.9 for 3 units, units, 1.4 for 4+ units 1.4 for 4+ units

1 https://minneapolis2040.com/goals/eliminate-disparities/ 2 https://lims.minneapolismn.gov/download/Agenda/1088/Built%20Form.pdf/47992/1921/Built%20Form 3 https://minneapolis2040.com/goals/affordable-and-accessible-housing/ stock, over 14,000 buildings in Interior Districts 1-3, is built on lots smaller than the proposed minimums.4 There are small lots that have gone undeveloped, in part because of lot size minimums. And large lots cannot be subdivided into parcels smaller than the minimum, which further limits options for development. However, smaller lots can sustain smaller buildings and unit sizes. Lowering minimum lot sizes could allow for expanded creativity and nimbleness in development, and increase the variety of housing options. At a time when we need to be developing more affordable units, we shouldn’t overlook the option of developing smaller buildings on smaller lots. For these reasons, we propose eliminating the minimum lot size for previously developed lots and setting a lot size minimum of 3500 sq. ft. for undeveloped lots.

Third, the affordability incentives as drafted fail to support affordability in a meaningful way, and instead further the racially inequitable impacts of exclusionary zoning. The Built Form incentives reward developments that exceed ordinance requirements—in features such as parking, affordability, or sustainability—with an increased FAR value. None of the proposed incentives are applicable for developments in Interior Districts 1-2. Moreover, the affordability incentive only kicks in for developments of 20 units or more. This is a problem. By reserving affordability premiums only for Districts with greater density, the Draft Built Form Regulations will further concentrate affordable housing in denser areas of the City. This preempts efforts to integrate affordable housing options into neighborhoods that formerly allowed only single-family homes. By limiting affordable development to denser areas, this incentive fails to promote mixed income communities throughout the city and would solidify the impacts of exclusionary zoning.

Instead, we propose revising the affordability incentive in the following ways. First, the affordability incentive should be extended to apply to developments in Interior Districts 1-2. Second, the incentive should apply to any Interior 1 project with 3+ units, and any Interior 2 project with 4-6 units. This means the City’s inclusionary zoning requirements would not apply, as they are specific to buildings of 20 or more units. As an alternative, we suggest that for developments of 3+ units in Interior 1 Districts, the inclusion of one unit affordable at 60% AMI would allow permission to add an additional, fourth unit, with a FAR increase of 0.2, to 0.8. For developments of 4-6 units in Interior 2 Districts, the inclusion of two units affordable at 60% AMI would allow permission to add 3 additional units per lot, as well as a FAR increase to 1.0-1.25. For developments of 10-20 units in Interior 3 Districts, the inclusion of three units affordable at 60% AMI would allow permission to add an additional floor. For Interior 3 developments of 20+ units, we suggest applying the City’s current inclusionary zoning standards, also to add an additional floor. See the table below. With these modifications, affordable housing options can be more easily integrated into lower-density neighborhoods. This will meaningfully incentivize the development of units that are affordable to a variety of households and meet a variety of household needs and preferences. These changes would promote mixed income communities and preclude the overt concentration of either wealth or poverty, which as we know, has significant implications for racial equity in our City.

Built Form District Affordability Standards Value of Premium Interior 1 (with 3+ At least one unit at 60% AMI Permission to add a fourth unit (FAR units) increases to 0.8) Interior 2 (with 4-6 At least two units at 60% AMI Permission to add 3 additional units units) per lot (FAR increases to 1.0-1.25) Interior 3 (with 10-20 - For 10-20 units, at least three units at 60% AMI Permission to add an additional units, or 20+ units) - For 20+ units, inclusionary zoning standards floor apply

4 https://streets.mn/2020/10/29/get-rid-of-minimum-lot-size-requirements/ 5 https://www.mhponline.org/images/stories/docs/research/NOAH-MPLS-final.pdf Regulations truly meet the needs of Minneapolis residents depends on this affordability mechanism. We strongly urge City leaders to extend affordability incentives to smaller developments in Interior Districts 1-2.

We are grateful to our partners at the City of Minneapolis for their dedication and tireless commitment to the residents of this City. Minneapolis 2040 has established a framework for bold and transformative change over the next twenty years. We believe that with some revision the Built Form Regulations can live up to the values of the 2040 Plan. Thank you again for the opportunity to comment on the Draft Built Form Regulations. We would be glad to answer any questions or offer clarification as needed.

Thank you.

Aeon Align Minneapolis The Alliance City of Lakes Community Land Trust Inquilinxs Unidxs Por Justicia Metropolitan Consortium of Community Developers (MCCD) Minnesota Housing Partnership Neighbors for More Neighbors Sierra Club North Star Chapter Twin Cities Habitat for Humanity Urban Homeworks, Inc.

November 9, 2020

Via email to [email protected]

Dear Minneapolis Planning Commission:

The Family Housing Fund (FHFund) is pleased to comment on the draft built form regulations proposed as part of the rezoning study for Minneapolis 2040 implementation. We support the City’s goals in the Minneapolis 2040 plan to increase housing supply and choice.

For the purposes of these comments, we are primarily focused on 2-, 3-, and 4-unit development, as well as Accessory Dwelling Units (ADUs), in Interior 1, 2, and 3 zones. FHFund, with several partners and with the participation of the City of Minneapolis, recently launched a Building Equity in Small Multifamily initiative to ensure longtime community residents with low to moderate incomes in Minneapolis cultural districts have the opportunity to purchase 2-4 unit buildings, become owner-occupant landlords, and build wealth through home equity and rental income. We believe this is a promising strategy to reduce racial wealth disparities, prevent displacement, and support local ownership and control of land. FHFund has also worked for several years to increase development of ADUs as a type of small-scale housing that can play an important role in addressing our region’s need for more affordable housing options.

We have identified several specific opportunities to strengthen the built form draft guidelines to help achieve the City of Minneapolis’s 2040 vision. These suggestions are consistent with the goals of the Minneapolis 2040 plan to increase housing options in neighborhoods, improve affordability, and close racial wealth gaps.

Overall, FHFund recommends adding incentives for affordability and additional housing units in Interior 1-3 zones. Specifically:

- Include tiered FARs, based on number of units, in Interior 1 and 2, just as are currently proposed in Interior 3. o This change would make it more feasible to develop small infill properties with 2- or 3- bedroom units. For example, under the current proposal, in Interior 1, the maximum residential unit size in a triplex is estimated at 600- 650 sq. ft. Increasing FAR limits (from .5, to .6 or .7, for 2- or 3- unit development, respectively) would provide more practical opportunities for increasing the number of housing units on each parcel, and allow a meaningful increase of up to 500 square feet of floor area per unit. - Include affordable housing incentives (layered on top of tiered FARs) for smaller-scale 2-, 3-, and 4- unit development—not only for 20+ unit development. o Allowing an increase in FAR tied to affordability, in Interior 1 and 2, would make it more feasible to develop 3-bedroom affordable units in duplexes and

triplexes – a needed housing type and price point that is rarely found in most Interior neighborhoods, outside of historic small multifamily building stock. o Allowing an increase in building height tied to affordability in Interior zones— e.g., allowing up to one additional story in Interior 3 for an affordable unit— would also increase the likelihood that new affordable units will be developed in small rental buildings. o These built form incentives could be designed to align with City programs such as Minneapolis Homes which support affordable homeownership. - Eliminate lot coverage rules specific to “primary” and “accessory” structure, especially if the accessory structure is dwelling space. o Building on-grade, accessible dwelling space is a common motivation for homeowners building ADUs. Detached ADUs are an opportunity for adding homes that are accessible to people with mobility challenges, within the context of established neighborhoods with older housing stock. o In the example of a typical 5,000 sq. ft. lot, with a principal house with a footprint of 1000 sq. ft and a garage with a footprint of 440 sq. ft., building an 800 sq. ft. addition to the main house would bring lot coverage to 45%. However, attaching the same 800 sq. ft. addition to the garage—or even replacing the garage with a new 800 sq. ft. footprint detached ADU structure, for a lower overall lot coverage ratio—would not be allowed under current proposals. - Allow a fourth unit by right in Interior 2 and 3 zones. o This change would be consistent with the typical “single-family” financing threshold for 30-year mortgages for owner-occupant landlords, and would increase wealth-building opportunities for owner-occupants. It would also have the practical impact of better differentiating Interior 2 from Interior 1.

These suggestions to modify the built form regulations changes proposed as part of Minneapolis 2040 can help to address key barriers to development in Minneapolis. Further, aligning these built form regulations with the City’s other programs, including the Minneapolis Homes and Missing Middle development programs, has the potential to create new affordable rental and ownership units.

Please feel free to contact me with any questions. Thank you for your consideration.

Sincerely,

Sarah Berke Program Officer 612.274.7690 [email protected]

*Include this in the city record

To whom it may concern. I am very concerned about the effect of the 2040 plan on Longfellow. I feel that it is a work of fiction meant to facilitate aggressive development. A work of fiction because it doesn’t even begin to address the real issues around how to increase affordability and density within the City. All it does is give a green light to whatever developers want to do.

The real problem with how to make Minneapolis more dense affordable is that putting up multiple dwelling units of reasonable size is no longer profitable. Figuring out how to facilitate the kind duplex or fourplexes, that fit on the existing lots, like the buildings that already exist around the city, would take real problem solving and probably more public-private cooperation to solve this dilemma.

Just getting rid of any real controls over developers does not solve this problem. Examples of what you get instead are the over-sized buildings 46th and46th, and the proposed one replacing Greg’s Auto on Minnnehaha Ave. They are too big for their lots. The building at 46th was intended to be luxury condos until the 2007 recession stopped this. Replacing affordable housing with luxury condos does not help make Minneapolis become more dense or diverse. It just makes it less affordable. The same is true of the mcmansions springing up all over Longfellow. Replacing small affordable houses with over-sized single family dwellings only benefits realtors and out-of-state developers with big pockets. I’m sure that the people who move into these houses are fine. I am also sure that if they want a mcmansion they can find one in a suburb. It might even cost less. If you want to live in Longfellow you can choose to live in a reasonably-sized house. The people that I have talked to value the neighborhoods of South Minneapolis. My neighborhood has been a working-class neighborhood with affordable housing that helped stabilize these families for generations. It’s the realtors and bankers who segregated these neighborhoods, not the residents. What many of us see is the devaluing and even plundering of what were remarkable neighborhoods under the guise of “increased density.” The justification that South Minneapolis has nothing worth preserving is both ignorant and offensive. It seems that our planning department makes big statements with no evidence of the hard work it would take to figure out what it would really take to make the stated goals happen. Instead, they just allow developers to wreak havoc on the existing housing stock. I think that with the squeeze of the city budget due to COVID, it would make good sense to simply defund the city planning office. I mean this sincerely., not sarcastically. Setting up some reasonable limits on what can be built on a particular lot and then leaving it up to chance and the economy would get a better result than the current pseudo-plan.

Very Sincerely, Gretchen Harry November 9, 2020 To: Minneapolis Planning Commission

[email protected] [email protected] [email protected]

FOR THE PUBLIC RECORD I am a resident and a thirty-six year homeowner and taxpayer in the City of Minneapolis. It has come to my attention that certain groups are now seeking to amend the ill-advised 2040 Plan to revoke promises made at the time of the adoption of that Plan. Specifically, at the time of adoption of the Plan families who had purchased single-family homes in reliance on a neighborhood maintaining its character were assured that, even though the Plan would overturn existing zoning for that neighborhood, any newly constructed two- and three-family homes in the neighborhood would still have to “meet the same height, setback, and massing requirements as single-family homes." It appears that since market forces are denying the 2040 Plan backers of the results they wanted (i.e., demand in the residential real estate market is currently for single family homes, with a dedicated home office space and sufficient outdoor space to allow for small, socially-distanced gatherings, thus making small triplexes with shared HVAC systems and little or no private outdoor space undesirable and not cost-effective for developers), they are now seeking to loosen restrictions further to make it easier for developers and non-owner occupants to destroy existing, stable city neighborhoods in the pursuit of “increased density.” The “increased density” assumptions underlying the 2040 Plan have been overturned by the COVID-19 Pandemic. Downtown as those of us who have maintained office space there for decades knew it, with a quarter of a million workers commuting in and out five days a week, is not going to return. Employers are now realizing that it is not necessary to require employees to shuttle back and forth to and from a central location on a daily basis and maintain costly office space that is only used for 10 or 12 hours a day. Working remotely has become the new normal, and with that the demand for suburban and ex-urban residential single-family real estate is exploding. As that trend continues and as the need for downtown administrative staff, retail store clerks, bank tellers, security and custodial staff and food service personnel decreases, the need for “increased density” in the city also disappears. The city is faced with the choice of either preserving the character of its existing residential neighborhoods so as to remain competitive with other residential options or watching its homeowner tax base make an exodus out of town.

In light of this, the Planning Commission and the City Council should give no further consideration to and should reject all of the following changes currently being demanded: 1. Approval of affordable dwelling units for lots where the principal residence is not owner- occupied. This would merely allow more non-resident investors to purchase and convert owner-occupied properties to investment property and to outbid potential home buyers who are willing to consider living in the city.

2. Any reduction or elimination of off-street parking requirements. City planners continue to imagine a city where no residents have cars. In fact, a quick trip down any street in an area where apartments have taken over (Uptown, for example – and I am a cyclist, so I see this from the perspective of a bike saddle and not sealed inside a car) reveals that this is not reality. City residents have cars, period (and for many of them, the plural “cars” is more accurate than the singular). Many city residents actually work in the suburbs and many make weekly or bi-weekly trips to visit family members who live well beyond the metro area. To pretend that these residents do not and will not have cars is to live in a fantasyland. Any policy that results in cramming more cars onto both sides of the streets in a city that is impacted by snow almost six months out of the year is not a good policy.

3. Variances to circumvent the rules established for Shoreland Overlay Districts. The common practice seems to be to establish rules and then ignore them by issuing a variance each time a developer steps forward with a request. The lakes and interior waterways are what distinguishes Minneapolis from other major cities. If we are going to preserve city neighborhoods, we need to enforce, honor and abide by the rules that have been established for that purpose.

4. Adding “premiums” for development in interior neighborhoods. Granting subsidies to for-profit entities to disrupt existing neighborhoods and depress the value of investments that owner-occupant homeowners have made in reliance on existing rules is unacceptable.

5. Changes to existing Interior Building Envelope, Setback and other requirements. As stated above, rules become meaningless if variances are granted on request or if the rules keep changing in response to developers’ requests. In this regard, existing requirements for Floor Area Ratios, Setbacks, Lot Coverage Ratios, and Building Height must be maintained as was originally promised and as homeowners relied on when choosing to buy homesteads in residential neighborhoods in the city. In the interest of maintaining a viable residential city, I respectfully request that the Planning Commission and City Council reject all of the above changes. David W. Koehser 1817 Irving Avenue South Minneapolis, MN 55403 Nov. 9, 2020

To: Minneapolis Planning Commission Minneapolis City Council Mayor Jacob Frey

From: Gayle Bonneville

RE: Built Form/2040 Comprehensive Plan comments

As a resident of Minneapolis’ “Blast Zone” of high-hazard freight rail, I feel it is imperative that the Planning Commission and City Council act immediately to incorporate built-form language into the 2040 Comprehensive Plan that protects the public health and safety of residents. Currently the plan fails to take into consideration the dangerous juxtaposition of high-hazard freight rail operations and high-density housing - a troubling mix on many levels.

The built-form guidance overlooks important safety and health considerations of adding high-density housing near active freight rail routes and shipping yards that regularly carry and host high-hazard trains and the accompanying diesel particulate matter at an alarming rate. Placing new housing, especially high-density multi-housing as the city is currently approving, is a risk-filled policy on both a short-term and long-term level. Short-term hazards stem from diesel particulate and substandard air quality from rail and its associated intermodal operations. Long-term hazards stem from the risky proposition of placing housing (increased population) in such close proximity to rail lines, particularly rail Iines carrying high-hazard and explosive freight such as anhydrous ammonia, chlorine, crude oil, propane and more.

This rush to add high-density housing in hazardous areas of our city needs to stop. A moratorium on new housing adjacent to rail lines should be in place for residential developments within at least a half-mile (standard Blast Zone) of rail Iines and rail yards hosting high-hazard freight.

I request that the City of Minneapolis study and adopt Canadian development review processes and standards that prohibit such residential developments near freight hazards that have unfortunately sprouted up throughout Minneapolis recently, particularly in northeast Minneapolis literally within feet of high-hazard freight lines.

If the City of Minneapolis instead prefers to roll the dice with residents’ health and safety, at a minimum the built-form regulations should:

• Require developers and property managers to disclose to residents and potential residents that a) hazardous and/or explosive commodities such as anhydrous ammonia, chlorine, propane and crude oil are being shipped via adjacent rail lines within a half-mile of their home, b) a danger of derailment also exists regardless of the hazard level of the commodities being transported, and c) that their proximity to additional diesel particular matter from rail and intermodal operations may impact the health of their family negatively. Diesel particulate from trains is a known pollutant and health hazard. • Post signage on site reflecting the above information. Adapt and/or adopt the above- mentioned Canadian development review procedures for new housing. • Define a new “Interior” residential category that compensates for high-hazard freight impacts on public health and safety, thereby reducing the density levels in these areas to protect public health and safety. • Revise other residential development categories in the Comprehensive Plan accordingly. • Devise a minimum amount of setback for new residential development of all sizes sited adjacent to rail, rail operations or intermodal operations that protects public health and safety. • Require citywide neighborhood-specific evacuation plans by emergency planners in case of a hazardous freight train derailment/spill/fire, etc. • Engage with community organizations such as Citizens Acting for Rail Safety-Twin Cities (CARS-TC) and impacted Minneapolis neighborhood organizations to flesh out detailed solutions to this serious miscalculation in the 2040 Comprehensive Plan.

Given that federal and local expectations are for affordable housing within a half-mile of transit stations, many of the housing units springing up in Minneapolis could be occupied by individuals/families with incomes below the area mean income and others considered vulnerable. It is irresponsible to expose any additional residents to this risk. November 9, 2020 Dear Minneapolis Planning Commissioners, We would like to weigh in on changes and additions in this overhaul of the built form regulations and zoning for the city of Minneapolis, since the passing of the 2040 Plan. We believe that these changes should have all been presented together and the changes should have been presented to the public in comparison to what the current rules are - so citizens can see the changes in their entirety and in relationship to existing rules. Despite the public process to pass the 2040 Plan, some groups like Streets.mn and Neighbors for More Neighbors, are now claiming that Minneapolis 2040 didn’t go far enough and are suggesting evaluating our existing neighborhoods again and “restarting the research of Interior neighborhoods” because they are not happy with the results. They are not even willing to evaluate what the Planning Commission is currently discussing and want to leapfrog over that, to install guidelines that give developers carte blanche. We would like to remind the Planning Commission (which also met extensively on 2040) that during the 2040 process citizens were assured “the expectation that two and three family homes in low-density areas must meet the same height, setback, and massing requirements as single family homes.” would occur. We heard this repeatedly and in writing from City Council members and Planning Commissioners. The current Interior 1, 2, and 3 building envelope must be maintained as promised: including Floor Area Ratio, Setbacks, Lot Coverage and Building Height. We are also against adding more “premiums” to interior neighborhoods. While premiums on transit corridors are appropriate - in interior neighborhoods it will add more height, shadowing, more impervious surface and less greenspace-all environmentally inappropriate and only aimed at more profitability for developers. Premiums should be specific and clearly spelled out in both corridor 4, 6 and transit 10 and specify what developers have to produce for added height and units. Shoreland Overlay District Guidelines should be maintained to protect our lakes and there should be a clear statement that the SOD guidelines take precedence over built form guidance. Height increase requests should not be a staff planning decision but a public hearing process each time there is a request to violate the SOD. ADU’s should not be built on lots where the principal residence is non-home owner coccupied. ADU’s are a good policy that needs to be left for those who are building equity in the home they own. Changing this will only benefit developers. Changing and eliminating parking maximums and minimums in our neighborhoods with no clear rationale other than wanting to eliminate cars hurts small businesses. Uptown is a case in point - eliminating parking in this area over the last year, has resulted in many empty storefronts and business closures. Many of the changes being advanced in these built form development discussions by the Planning Commission and staff would result in a totally staff-driven approval process instead of conditional use permits, variances and height, setback changes and premiums being brought to the neighborhoods that the projects are in, for discussion and approval. Given that we participated in the 2040 process and received assurances about what would happen and the guidelines for interior 1, 2 and 3, and now finding out less than a year later, the city is going back on its word, doesn’t build trust. Sincerely. Lisa McDonald Minneapolis for Everyone

VIA EMAIL

November 9, 2020

Planning Commission City of Minneapolis

Re: Comment on the Draft Built Form Zoning Regulations

Dear Members of the Minneapolis City Planning Commission:

The Housing Justice Center is a Twin Cities based public interest law firm focused on affordable housing, with a long standing interest in ways local government policies can promote affordable housing. We write now to make two comments on the proposed Building Form standards now before the Planning Commission.

Use of Premiums to Support City Goals The standards provide developers with increased density opportunities in exchange for developer commitments to provide certain premiums to accomplish various city goals. The premiums, or ways developers can access more density, are numerous. They include on site affordable housing, grocery stores, child care centers, reduced carbon footprint, local historic designation, outdoor open space, high quality construction, enhanced public realm, green roof, extra landscaping, and more.

All these are worthy goals, but when this many public goals are called out as priorities, none are likely to experience meaningful progress. On the other hand, if one thing is clear from public input and previous statements of virtually all elected officials in the city, affordable housing is supposed to be a priority.

We know from past experience that a density bonus policy tied to affordable housing does not necessarily lead to more affordable housing. Past city policy rewarded developers with more density if they either included affordable units or built structured parking. In virtually all cases developers opted for structured parking and no additional affordable housing was produced by the policy. That policy only included two options, not the numerous options proposed in the density bonus section.

Which premiums developers will opt for will depend on which premiums align with goals developers already have, as well as how the premium affects their financial bottom line. For on-site affordable housing to be a serious option, the details of the various premiums will need

to be structured so that choosing affordable housing is an attractive option compared to the many others the developer can choose from.

Accomplishing 2040 Goals for smaller residential properties HJC also supports the comments of Make Homes Happen urging changes so that greater density opportunities are available for smaller lots and residential properties within the City. Such changes would appear to be particularly helpful where nonprofit developers are seeking locations to construct affordable housing or in the case of properties in high cost markets. Without additional incentives it is unlikely that small scale infill development will include affordable housing opportunities. With the incentive of significant density opportunities, waiver of minimum lot size requirements, and other regulatory easing in exchange for creating opportunities that are affordable, we believe that the 2040 plan can come closer to meeting its stated goals.

We also believe that this is the time for the city to remedy a barrier to additional affordable rental housing development in the ADU regulations. The rationale for the limitation of ADUs to owner occupied homes is without justification – the findings for the limitation rest on “neighborhood appearance and character” without the type of evidence that there is a difference between an ADU on an owner versus a renter occupied property. This has been a challenge for increasing the amount of density and affordability and created barriers for nonprofit developers looking to utilize ADUs as a source of affordable housing. There are potential fair housing implications to this type of distinction between owner and renter occupied housing.

Truly,

Margaret Kaplan President, Housing Justice Center

Dear Planning Commissioners and Council Members, 11/09/2020

I am writing concerning potential amendments to the 2040 plan to building code, including lot coverage, floor area ratios, building heights and set back requirements for multiple family construction. Specifically, Minneapolis residents were told what the 2040 plan would look like for neighborhoods and promises and definitions were made to Minneapolis residents concerning interior 1-2-3 multiple family dwellings. I am opposed to changes to the building code expectations and outcomes that were made to the public.

I oppose changes to set backs and the scale of proposed multiple family builds. It is not environmentally conscious or sustainable to increase the footprint and scale of multiple-family builds because of the negative impact this change would have on mature trees and other shrubs or plants that exist on lots. Even with current rules many of these hard working carbon fighters are routinely destroyed without consideration for new construction. If the 2040 plan and the city, are truly concerned about carbon remediation (a significant element claimed to be central to the plan) they need to not even consider expanding the destruction zone and scale of multiple-family builds. We need our mature carbon fighters to support a healthy city. Replanting young trees cannot replace the oversized positive benefit of mature trees and other mature plants. Additionally pollinators and birds need to have their neighborhood habitats protected.

Allowing setbacks and height requirements to be relaxed, where setbacks are not consistent with existing neighborhood setbacks to the front, rear and sides of the property, is not only a visual planning disaster, but also will threaten to shadow adjoining properties and the sun seeking plants and trees on those properties. Additionally these sort of changes lead to the feelings of despair to affected homeowners. Many Minneapolis residents work hard to support pollinators, birds, and helpful bugs, by providing native plant habitat on their properties to support a healthy Minneapolis. It is not forward thinking to shadow out adjoining properties, while owners try to support green initiatives. Minneapolis 311 recordings remind us to support pollinators in our yards; the 2040 plan should only support development that does the same.

Additionally, oversized structures, which do not follow neighborhood setbacks create water run off problems for both neighbors and the storm drain system. Every property needs to have adequate green space to accommodate water absorption for an environmentally sound plan.

I think it is fine to place previously defined multiple family units on appropriately sized lots, which accommodate previously agreed to setbacks to property line boundaries and previously defined height requirements. If a given potential lot is to small to accommodate these previously defined parameters then I disagree with amending the 2040 plan to remove project scale, height and setback requirements that have been provided to Minneapolis residents. Perhaps these small lot properties, should be reduced size single-family builds designed for the same target families who would occupy a potential duplex or triplex and be built to comply to existing scale and setback rules . The desire to create access to neighborhoods, or develop neighborhoods should not supersede the limitations of any given potential lot, or environmentally sound decisions.

I also believe that existing homes potentially converted to multiple dwellings must be regulated, limited to owner occupied properties and be limited to no more than one to two additional living units. Furthermore any such property should be required to provide some off- street parking.

Finally environmentally conscious attitudes and actions must apply to shoreland overlay districts and any variance must include a public hearing for every requested variance.

In closing, If Minneapolis wants to have a 2040 plan that is what it claims to be, then it needs to be rooted in environmentally sound decisions that supports people, neighborhoods, and the species that make up our green environment and by the way, ultimately support our very existence.

Thank you, Anne Feicht zip code 55410

Dear Planning Commissioners and Council Members - Please make these comments a part of the PUBLIC RECORD.

Ref: Proposed increase of increase density and elimination of development restrictions currently in place under 2040. To all who are and must be concerned,

My family has resided in Northeast Mpls since the early 1950s and remain active members of a vibrant and growing Ukrainian and multi ethnic community.

Our churches are here, our stores, our community, our roots and long history in an area which has, and continues to draw Ukrainians and others to an area valuing the cultural, ethnic diversity of our community and the ability to live in a friendly community not overwhelmed with towering condos and structures potentially destructive of the peaceful, beautiful river front community in which we live.

During the debate on 2040, there were many confirmations and promises related to Built Form for Interior 1-2-3.

We were assured "the expectation that two- and three-family homes in low-density areas must meet the same height, setback, and massing requirements as single- family homes."

Now certain special interest groups are suggesting that tax dollars fund a consultant,.Opticos, to "evaluate our existing neighborhoods" and "restart the research of Interior neighborhoods."

These groups are targeting Interior 1, 2 and 3 residential neighborhoods claiming

"Minneapolis 2040 did not go far enough". ( streets.mn post on October 2nd by Janne Flisrand.}

Their objectives are clear:

Up zoning everywhere in the city, teardowns of existing affordable housing for four plexes, lack of parking for new developments, elimination of neighborhood small area plans and the shoreline ordinance, and destruction of neighborhood character to name but a few objectives.

There should be NO CONSIDERATION to change these areas:

Asking the City to increase building heights, reduce setbacks, eliminate minimum lot sizes and increase buildable area on a lot. NO

Asking to relax all the rules particularly in Interior 1, 2, and 3 as they feel those are the “whitest and wealthiest” neighborhoods in the city and the most exclusionary neighborhoods for affordable housing. NO They don’t want any hearings for variances and conditional use permits either. YES They want to change zoning to add more units and buildings on city lots. NO They are citing almost 14,000 lots so small in Minneapolis you would not be able to build on them under current draft regulations. Even though they are characterizing this array of “smaller” lots as a justification to eliminate minimum lot sizes, these can be built on if a variance is pursued. They are actively working to manipulate the city council to change the approved 2040 plan and remove regulations in Interior 1, 2 and 3. Clearly this is NOT to create more affordable housing, but make it easier and more profitable for developers. The units currently under construction, of which there are many, are beyond the financial means of our residents and those who would like to reside in this area, never mind addressing the complexities surrounding excessive housing units in an area unsuited to large numbers of condos which can affect safety, our riverfront environment, etc. .

Our neighborhood strongly supports the following 1. Current Interior 1-2-3 building envelope must be maintained as promised: (Floor Area Ratio; Setbacks; Lot Coverage; Building Height).

• Continue to respect the patterns and forms that exist in our neighborhood interiors. • Do NOT increase the max FAR for Interior 1, 2 & 3 (.05, .08, 1.4) • Do NOT lower the lot size minimums from 5000-6000 sq feet.

2. "Premiums" to Interior neighbors for developers make their projects more profitable at the cost of our single family, duplex, triplex neighborhoods. Premiums on transit corridors is appropriate, and that provides adequate

density without destroying interior neighborhoods. Premiums should be limited in Interior 1, 2 & 3.

3. ADUs should be built on lots where the principal residence is owner- occupied. Allowing ADU’s on non-owner occupied only turns over our NOAH properties to investors instead of local home owners. Investors will clamor to turn one small house or duplex into 3-4 unit property and regular residents won't be able to compete.

4. Elimination of off-street parking minimums and re-evaluation of parking maximums. This is a gift to developers with the livability of our neighborhoods at risk. The ONLY place this should be a possibility is transit corridors. We live in MN, with MN winters, cars are a necessity unless there is transit within 2 blocks of every home.

Any changes to ease the requirements would hurt our neighborhoods and discourage home ownership by encouraging developers to tear down single family homes to build large multi family.

With the major large units currently under development, let’s see how this accommodates new residents, supports moderate growth, while respecting and allowing current residents to enjoy the community we built.—and then take a look as needed down the road.

Sincerely,

Luba Lewytzkyj & Bob Morris 95 6th Ave NE, Mpls 55413 952.440.5822

From: Alissa Pier Sent: Tuesday, November 10, 2020 10:54 AM To: Lara Norkus-Crampton ; Baldwin, Lisa M. Subject: [EXTERNAL] Re: Please Rethink the Built Form Recs for 2040

Hello Lara,

Thanks for your email. I am forwarding it to the clerk for the public record.

I also wanted to make you aware of a few things:

1.) While the public hearing on this item was opened last night (11/09/2020) for testimony, the full staff presentation will occur next Monday, November 16, and additional public testimony will be taken at that time. This is because our meeting last night lasted almost 6 hours, and the commission felt that we needed to allow for adequate opportunity for the public to testify on this item, given the late hour and time spent waiting during other deliberations.

2.) Just to clarify a concern called out in your correspondence: at the Committee of the Whole (11/05/2020), the commission met for over 3.5 hours, not one hour.

Stay safe, stay healthy, Alissa D.Luepke Pier, AIA

On Mon, Nov 9, 2020 at 11:58 AM Lara Norkus-Crampton wrote: Dear Commissioners,

I was listening to the last Committee of the Whole meeting and was astounded that commissioners had less than an hour to discuss, much less understand, a 327 page document. And this plan, as proposed, will bring profound changes to the built environment of our city with very little study or understanding of the impact of so much density, and so little emphasis on preserving green space/habitat or tree canopy (already not meeting the city’s stated goal of 40% coverage) while a pandemic and climate change is having a huge impact on our city’s ecosystems and public health in real time.

New developments being encouraged to be built up to 10 stories and bulked up with increases in FAR for very little in return, sends a message to speculators that Mpls is open for business and that our urban design standards are very low.

We are not Detroit. Much of our housing stock could last another 50 to 100 years. In ECCO, most of our neighborhood is R2B— meaning it already is made up of 30 to 35 foot houses that are made up of single-family, duplexes, and triplexes. We also have some traditional brownstones that are fourplexes and up but low in scale. We call that well integrated density.

Our neighborhood as of 2010 was 70% rental. Now with the density brought to our neighborhood by sons of Norway – – that percentage is much higher.

And yes, Corridors like Lake Street go through commercial centers like Uptown. Lake street also crosses the chain of lakes— which is considered critical habitat for migratory birds and is already suffering in terms of water quality due in part to pollutants flowing directly into the lakes from storm sewers (including busy roads like Lake St) and climate change making the lakes much warmer and excellent habitat for invasives and algae.

I agree very much with the letter my neighborhood board sent regarding concerns regarding the built form recommendations, which seem overly permissive and with mostly only administrative review.

9/10/20 Full Built Form Regs Memo regarding 2040 https://lims.minneapolismn.gov/download/Agenda/1088/Built%20Form.pdf/47992/1921/Built%20Form

Question: Why are these built form regulations allowing up to six stories on Parkland in direct contradiction with regulations on height set forth in the Shoreland Overlay District?

(I have not been able to locate further information in the final draft of parkland built form regulations.)

Page 8 of the memo says that buildings and parks can go up to six stories/84 feet. My understanding has always been that the promise of density in urban areas is to concentrate people in some areas to preserve existing green space for habitat, lowering CO2/heat island effect and for healthy recreation – not to be viewed as underutilized real estate.

Minimal amenities required For maximum height and increases in FAR. This seems especially egregious on the limited amount of green space and habitat we are trying to preserve for people as well as pollinators and other creatures with whom we share our ecosystems.

Why is parkland being awarded more height and bulk (FAR) for “affordable housing, public open spaces, enhanced public realm and through-block connections“? By their nature, parks are public open spaces, have enhanced public realms and plenty of through block connections. This points to the weakness of the proposed premium system. As currently described it would allow most developers to increase the heights and massing of their developments from from 4 to 6 stories in Corridor 4; 6 to 10 stories in Corridor 6, or from 10 to 15 in Transit 10 via administrative review without requiring much extra effort or meaningful upgrades to mitigate the potential environmental and livability impacts of such increases in scale and density. (Pgs 21-25 Built Form staff report)

Where are the quantifiable metrics to evaluate whether we are meeting the stated 2040 goals of “healthy air, clean water, and a vibrant ecosystem”?

8/20/20 COW discussion: https://lims.minneapolismn.gov/download/Agenda/964/Built%20Form.pdf/47344/1862/Built%20Form %20Regulations

Page 4 Minneapolis 2040: • Goal: “High-quality physical environment: In 2040, Minneapolis will enjoy a high-quality and distinctive physical environment in all parts of the city.” • Goal: “Clean environment: In 2040, Minneapolis will have healthy air, clean water, and a vibrant ecosystem.” • Goal: “Climate change resilience: In 2040, Minneapolis will be resilient to the effects of climate change and diminishing natural resources, and will be on track to achieve an 80% reduction in greenhouse gas emissions by 2050.”

Allowing more 10 story buildings around Lakes and treating existing habitat/green space in parks as prime real estate does nothing to provide vibrant ecosystems— at a time when all of our ecosystems are under great stress due to the impacts of climate change and pollutants.

Creating more shadowing and wind tunnels does nothing to encourage more walking, biking, and busing.

We can do better. I would urge the planning commission and the city Council two more thoroughly review these built form recommendations to try to create a plan that will actually achieve the stated environmental goals of the 2040 plan.

Thank you, Lara Norkus-Crampton ECCO Neighborhood

~~~~~~

October 26, 2020

Dear City Council Members and Members of the Planning Commission,

The ECCO Neighborhood Association Board welcomes the opportunity to provide feedback on the CPED’s plans to codifying the built form regulations outlined in the 2040 Plan, in particular the proposed premium system. Our neighborhood has been a focal point for controversies around development in Minneapolis in recent years, and we have been deeply engaged in thinking about and discussing these issues. We seek to encourage thoughtful development while also preserving the livability of our neighborhood and our nearby jewel, Bde Maka Ska, and we broadly support the goals of the 2040 Plan.

We do, however, have some significant reservations with the proposed plans as outlined in the September 10, 2020 Memorandum and as elaborated in the public meetings this fall. We hope you will take our views into consideration as you proceed with this plan. Our two main suggestions, outlined below, are:

1. The definition and application of premiums to built form regulations need to be more robust and specific. 2. The process for application of the Shoreland Overlay District (SHO) and other overlays needs to be spelled out clearly.

The 2040 Plan increased the permitted heights along the edges of our neighborhood quite considerably. For example, along most of Lake Street (Corridor 6) in our neighborhood, the height increase in zoning regulations goes from the existing 2.5 or 4 stories up to 6, and the current premium proposal would allow up to 10 stories, which in our estimation is simply too high for this area of the city.

We feel the premium system as currently described is simply too permissive, and would allow most developers to increase the heights of their developments from 6 to 10 stories (or from 4 to 6 in Corridor 4, or from 10 to 15 in Transit 10) without much extra effort or meaningful concessions. We would advocate for much more robust language in the premium descriptions, to make it more exceptional to award extra stories beyond the 2040 plan’s guidelines for Corridor 4, Corridor 6, and Transit 10.

To note a few examples:

• "Enhanced public realm” has no definition in the September 10 Memorandum (p. 22), and we wonder how is it different from another, separate premium "Outdoor open space", which has fairly basic standards that we imagine a developer would be likely to include anyway.

• Relatedly, we can imagine it not being terribly difficult to create a “Through-Block Connection” that is both public and outdoor, and a developer receiving 3 extra stories quite effortlessly. We would strongly advocate for the inclusion of language that would prohibit potential double- or triple-dipping—that is, that a single amenity could qualify for 2 or 3 premiums and then 2 or 3 extra stories would be granted.

• To fulfill the “Affordable Housing” premium, it appears the developer of a large (50+ unit) project need simply to follow the City’s current inclusionary housing requirement and add one more affordable apartment or two, and they will receive this premium. Or, they will simply

1. The definition and application of premiums to built form regulations need to be more robust and specific.

2. The process for application of the Shoreland Overlay District (SHO) and other overlays needs to be spelled out clearly.

3. The need to include the affordable housing on-site. This strikes us as quite easy for a developer to fulfill and does not merit an extra story. We support this goal in the 2040 Plan, but would like a developer to include many more units to receive an extra story.

• Most recent development along Lake Street (and Hennepin) has included commercial space on the ground floor, because it is in the financial interest of the developer. It thus appears that many/most developers will receive a premium for doing something they’d likely already do.

These are just a few examples, but seems to us that the proposed premium system makes it relatively easy for a developer to go from, for example, 6 to 10 stories without much extra effort. Given that heights in these areas have been zoned until now at 2.5 to 4 stories, a jump to 10 stories would produce buildings in our neighborhood that are significantly out of scale with respect to the existing built form.

And a final note: we in the neighborhood have long advocated for thoughtful development around Bde Maka Ska, which is important to both residents of and visitors to our neighborhood. We have consistently encouraged respect for the Shoreland Overlay District (SHO) guidelines in order to protect the lake. We are pleased that the SHO height regulations will be maintained (Memorandum, p. 34), and we would request a clear statement that the SHO guidelines take precedence over the built form guidance. Indeed, we would appreciate the same language that on page 9 related to going above the proposed new maximums for height: “Height increase requests that exceed the values in the table will require a comprehensive plan amendment and a rezoning, which must be adopted by the City Planning Commission and City Council as part of a public hearing process.”

Thank you for considering our views.

Sincerely,

The ECCO Neighborhood Association Board cc: Mayor Jacob Frey Janelle Widmeier, Principal Planner Joe Bernard, Planning Project Manager Jason Wittenberg, Planning Manager

From: steven Verdoorn Sent: Tuesday, November 10, 2020 10:17 AM To: Wittenberg, Jason W. ; Baldwin, Lisa M. ; 2040 <[email protected]> Subject: [EXTERNAL] Opposed to Prroposed changes to Zoning

There should be NO CONSIDERATION of further movement in these areas:

1 - Approval of ADUs to be built on lots where the principal residence is non-owner- occupied. NO! This only turns over more of our NOAH properties to investors instead of local owners, making it impossible for first time homebuyers to have a shot. Investors will clamor to turn one small house or duplex into 3-4 unit property and regular residents won't be able to compete. It also stuffs more people and impervious surface on a lot and eats up greenspace.

5 - Current Interior 1-2-3 building envelope must be maintained as promised: - Floor Area Ratio - Setbacks - Lot Coverage - Building Height

Thank you,

Steven Verdoorn

From: John Speltz Sent: Monday, November 9, 2020 7:40 PM To: Wittenberg, Jason W. ; Baldwin, Lisa M. ; 2040 <[email protected]> Subject: [EXTERNAL] 2040 NO NO NO

Planning Commissioners and Council Members,

There should be NO CONSIDERATION of further movement in these areas:

• Approval of ADUs to be built on lots where the principal residence is non-owner- occupied.

• Elimination of off-street parking minimums and re-evaluation of parking maximums.

• Strict Shoreland Overlay Districts

• Adding "premiums" to Interior neighborhoods. NO

• Current Interior 1-2-3 building envelope must be maintained as promised

Thank you

From: Julie Michener Sent: Monday, November 9, 2020 4:26 PM To: Bender, Lisa ; Erazmus, Kristina ; Wittenberg, Jason W. Subject: [EXTERNAL] Today’s Planning Commission

I am a resident of South Uptown and I am in complete support of more affordable housing options. However, throwing out controls that protect the legitimate rights of current property owners and support the environment and liveability of neighborhoods isn’t the correct path either.

I have to say the suggestions contained in this email seem extreme and I doubt they will create the outcome they are looking for. You will get developers constructing buildings for rich tenants without any thought to those around them or the environment.

https://mailchi.mp/bcf6ed867dc2/action-alert-help-save-over-300-affordable-homes- 5852744?e=0ea894a88d)

Thank you for your attention.

Julie Michener 3529 Girard Ave S Minneapolis 55408

From: Kaia Svien Sent: Tuesday, November 10, 2020 1:07 PM To: Wittenberg, Jason W. ; Baldwin, Lisa M. ; 2040 <[email protected]>; Cano, Alondra (External) Subject: [EXTERNAL] City Zoning Standards

Planning Commission Members, Staff, and Councilperson Cano,

I fully endorse the statement below. Please enter my submission into the Public Record.

Thank You, Kaia Svien 3632 13th Ave S, Mpls

During the debate on 2040, there were many confirmations and promises related to Built Form for Interior 1-2-3.

There should be NO CONSIDERATION of further movement in these areas:

1 - Approval of ADUs to be built on lots where the principal residence is non-owner- occupied. NO! This only turns over more of our NOAH properties to investors instead of local owners, making it impossible for first time homebuyers to have a shot. Investors will clamor to turn one small house or duplex into 3-4 unit property and regular residents won't be able to compete. It also stuffs more people and impervious surface on a lot and eats up greenspace.

5 - Current Interior 1-2-3 building envelope must be maintained as promised: - Floor Area Ratio - Setbacks - Lot Coverage - Building Height

Kaia Svien, MS Spiritual Guide, Meditation Instructor, Program Designer Mindfulness for Changing Times www.mindfulnessforchangingtimes.com [email protected] 612-722-2650 pronouns: she, hers

From: Melissa Licht Sent: Monday, November 9, 2020 3:00 PM To: Wittenberg, Jason W. ; Baldwin, Lisa M. ; 2040 <[email protected]> Cc: Gordon, Cam A. Subject: [EXTERNAL] the 2040 plan is already bad enough, thank you!

Dear City Planning Commission Staff and Cam Gordon,

On short notice, I am not able to make the meeting this afternoon, but want to make these comments part of the PUBLIC RECORD.

Please do not add to the 2040 plan’s disruption of neighborhood livability.

1 - Do not approve of ADUs on lots where the principal residence is non-owner- occupied.

2 - Do not eliminate off-street parking minimums; maintain parking maximums.

3 - Respect Shoreland Overlay Districts.

4 - Do not add "premiums" to Interior neighborhoods. Premiums on transit corridors can provide adequate density without destroying interior neighborhoods.

5 - Maintain current Interior 1-2-3 building envelope zoning: - Floor Area Ratio - Setbacks - Lot Coverage - Building Height

Thank you,

Melissa Licht Ward 2

From: Mike Welna Sent: Monday, November 9, 2020 2:58 PM To: Wittenberg, Jason W. ; Baldwin, Lisa M. ; 2040 <[email protected]> Subject: [EXTERNAL]

There should be NO CONSIDERATION of further movement in these areas:

1 - Approval of ADUs to be built on lots where the principal residence is non-owner- occupied. NO! This only turns over more of our NOAH properties to investors instead of local owners, making it impossible for first time homebuyers to have a shot. Investors will clamor to turn one small house or duplex into 3-4 unit property and regular residents won't be able to compete. It also stuffs more people and impervious surface on a lot and eats up greenspace.

5 - Current Interior 1-2-3 building envelope must be maintained as promised: - Floor Area Ratio - Setbacks - Lot Coverage - Building Height

Thank you,

Michael Welna Ward 13 Resident

From: Stephanie Belseth Sent: Tuesday, November 10, 2020 6:12 AM To: Wittenberg, Jason W. ; 2040 <[email protected]>; Baldwin, Lisa M. ; Palmisano, Linea Subject: [EXTERNAL] Reject changes to 2040 plan