2016-07-12 PC Agenda Packet
PLANNING COMMISSION MEETING
Tuesday, July 12, 2016
7:00 PM
1. CALL TO ORDER - ROLL CALL – ADOPT AGENDA
2. MINUTES
June 14, 2016 Planning Commission Meeting (pages 1-7)
3. PUBLIC HEARINGS
a. None.
4. OTHER BUSINESS
a. Discussion of Temporary Family Health Care Facilities (pages 8-14)
b. Planning Commission Training
5. ADJOURNMENT
1
ALBERTVILLE PLANNING COMMISSION
TUESDAY, JUNE 14, 2016
DRAFT MINUTES
ALBERTVILLE CITY HALL 7:00 PM
1. CALL TO ORDER – ROLL CALL – ADOPT AGENDA
Chair Klecker called the meeting to order at 7:00 p.m.
Becker conducted roll call.
Present: Chair Klecker and Commissioners Dominick, Edgren, Barthel, Wegner, and Council
Liaison Hudson.
Absent: Commissioner Brempell.
Others Present: City Planner Alan Brixius, Building Permit Technician Maeghan Becker,
Barbara Schneider, Dean Mabson, Scott Dahlke, Ralph Munsterteiger, Mike Mcshane, Donald
Savitski and Anne Savitski.
Motioned by Dominick, seconded by Barthel, to approve the agenda as presented. Ayes:
Klecker, Dominick, Edgren, Barthel, and Wegner. Nays: None. Absent: Brempell.
MOTION DELARED CARRIED.
2. MINUTES
Motioned by Barthel, seconded by Dominick, to approve the February 9, 2016 Planning
Commission meeting minutes. Ayes: Klecker, Dominick, Edgren, Barthel, and Wegner. Nays:
None. Absent: Brempell. MOTION DECLARED CARRIED.
3. PUBLIC HEARINGS:
A. Request to Rezone Outlot A, Heuring Meadows from B-2, Limited Business to
B-2A, Special Business District.
Brixius explains that the Leuer-Munsterteiger Properties is requesting to change the zoning on
Outlot A from B-2, Limited Business to B-2A, Special Business District to expand the range of
commercial uses that may be approved for the property.
Planning Commission Meeting Minutes 2
Regular Meeting of June 14, 2016
1. The proposed action has been considered in relation to the specific policies and
provisions of and has been found to be consistent with the official City Comprehensive
Plan.
The Albertville Vision Study guides this site for future commercial land uses. This
change in zoning will expand the scope of commercial businesses that may be approved
for this site.
2. The proposed use is or will be compatible with present and future land uses of the area.
The site is bordered by the following land uses: Cottages of Albertville/single family, 53rd
Street NE/commercial, CSAH 19/commercial, and a single family neighborhood to the
west. In 1989, Outlot A was created with the Heuring Meadows Subdivision with the B-2
zoning. At that time, the City Council created a 500 foot commercial strip along both
sides of CSAH 19 between I-94 and 50th Street NE.
Dominick mentioned that this was the property that West Bridge Church was considering
using.
3. The proposed use conforms with all performance standards contained herein.
The applicant has presented a concept plan for a combination of commercial and multiple
family residential to the City Council. To date, nothing has progressed. Any future
development plans must comply with City zoning performance standards.
4. The proposed use will not tend to or actually depreciate the area in which it is proposed.
The change in zoning will not change the land use, therefore no additional impact is
anticipated with the change of use.
5. The proposed use can be accommodated with existing public services and will not
overburden the City’s service capacity.
Future development will be within the capacity of available utilities, due to the area being
planned for commercial development already.
6. Traffic generation by the proposed use is within the capabilities of streets serving the
property.
As development begins to arise, there will be a required study to determine the type and
extent of transportation improvements that would be required to address both site access
and egress and dispersal of traffic.
The applicant has stated that the current zoning of B-2, Limited Business District is too
restrictive for commercial development. The B-2A District would help expand the scope of uses
and provides additional performance standards to protect the residential neighborhoods. Based
on the above mentioned, we recommend approval of this request.
Dominick asked about any potential suitors for the property. Ralph Munsterteiger responded that
they have had multiple suitors for the property, but they have not worked out to date. Dominick
asked how many suitors they have lost out on due to the current zoning on the property. Ralph
Munsterteiger responded with about a half dozen within the last 15 years, due to the current
Planning Commission Meeting Minutes 3
Regular Meeting of June 14, 2016
zoning. Munsterteiger gave an example that with the current zoning restrictions, any buyer
would not even be able to put a drive-thru restaurant on the property.
Klecker shows high concern for this property and what type of uses might come along with the
change in rezoning to B-2A. Klecker is concerned for the residential houses on Kalland Avenue
NE that come up to the property in question for rezoning. Wegner also expressed concern for any
of those residents that might be opposed to the rezoning request.
Klecker and the Leuer-Munsterteiger discussed the issues of why the property may not be
selling.
Motioned by Dominick, seconded by Edgren to open the Public Hearing. Ayes: Klecker,
Dominick, Edgren, Barthel, and Wegner. Nays: None. Absent: Brempell. MOTIONED
DECLARED CARRIED.
No one wished to speak for the open hearing on this issue.
Motioned by Barthel, seconded by Dominick to close the Public Hearing. Ayes: Klecker,
Dominick, Edgren, Barthel, and Wegner. Nays: None. Absent: Brempell. MOTIONED
DECLARED CARRIED.
Motioned by Dominick, seconded by Edgren to approve the Request to Rezone Outlot A,
Heuring Meadows from B-2, Limited Business to B-2A, Special Business District.
Ayes: Dominick, Edgren, and Wegner. Nays: Klecker, Barthel. Absent: Brempell.
MOTIONED DECLARED CARRIED.
B. Public Hearing to Consider a Request by Taco Bell for Site and Building Plan and
Conditional Use Permits for Joint Parking, Drive-Through Service Lane, and
Outdoor Dining.
A developmental application has been submitted by Border Foods to build a 2,690 square foot
Taco Bell restaurant at 6040 Labeaux Avenue NE. The zoning is accurate for the restaurant
request. The applicant will also need the following three conditional use permits to operate at the
proposed site:
1. Conditional Use Permit for Drive-Through Service Lane
2. Conditional Use Permit for Outdoor Dining
3. Conditional Use Permit for Shared Parking
The applicant will also need to obtain a demolition permit for the removal of the car wash and
materials, which is currently on the proposed site.
The zoning is B-3, Commercial Highway District, which allows restaurants as permitted use.
Through the conditional use permits, the outdoor dining, drive-through, and shared parking will
be allowed.
The lot area and setbacks meet the B-3 District standards.
Planning Commission Meeting Minutes 4
Regular Meeting of June 14, 2016
The lot coverage meets the City Code standards at 72.7% with the proposed project. The B-3
Zoning District allows up to 80% of the lot area to be impervious surface.
The proposed site access will not change from existing conditions. There is access from CSAH
37 and there is also a right-in/right-out access point on CSAH 19. No changes in access points
are being required.
Parking will need to be completed through a conditional use permit as the site shares access and
parking with DJ’s Hardware. Both of these sites are owned by Don Savitski. Border Foods will
be holding a land lease with Mr. Savitski remaining the owner of the site. Provided that
easements and leases are in place, the two lots may share access and available parking through
the conditional use permit. The applicant states that the total parking on both sites is 114 stalls,
and the site plan only shows 100 stalls. Staff’s estimate of required parking is 110 stalls for both
of the sites. The applicant must confirm that the two sites have the required parking count.
The site plan must be revised to show compliance with the required five foot parking setbacks.
The drive-through service lane, the two easternmost and western parking stalls fail to meet the
setbacks. City Code also requires that parking stalls must be 9 feet wide and 20 feet deep. After
review of the site plan, the parking stalls along the building and the west lot line only have an 18
foot depth. This must be corrected to the 20 foot depth to meet code. The City will require DJ’s
Hardware parking lots to be striped as a condition of the joint parking conditional use permit.
Currently, The Taco Bell site provides two disability stalls and DJ’s provides one stall. To meet
ADA requirements, this site needs to have one disability parking stall for every 25 parking stalls.
This must be demonstrated in the site plan.
Due to the City Zoning Ordinance, any parking lots of five plus cars need to be screened from
the public street. Therefore, a landscape hedge will be required along the west end of the parking
lot.
The site plan must also identify the snow storage areas exclusive of the required parking. The
snow removal cannot present a hazard to public streets or reduce the amount of required parking.
Deliveries to the restaurant will be along the north side of the building. The applicant must
describe the types of vehicles that deliver products to the restaurant and what that schedule will
be. The current site design does not accommodate the turning of a semi-truck through the site.
Brixius made the following comments for the drive-through service lane.
1. To move the menu board to the south side of the proposed patio would allow the stacking
of four cars waiting to order.
2. The location of the menu board and intercom should be direct toward either CSAH 19 or
CSAH 37 to prevent any noise issues.
3. The drive-through service lane is required to be screened and additional landscaping will
be required along the south edge of the drive-through lane.
Planning Commission Meeting Minutes 5
Regular Meeting of June 14, 2016
After staff discussion, there are going to be improvements made as a City/County project. These
improvements are an additional crosswalk and landings to accommodate pedestrian movement to
the four quadrants of the CSAH 19/CSAH 37 intersection.
The outdoor dining site plan shows a 237 square foot area on the west side of the building. There
will be a pergola providing partial covering.
For the outdoor lighting, the photometric plan did not include wall mounted lights on the
building. There was wall packs shown over each building entrance and the drive-through service
window. The applicant must provide more information on these fixtures.
Brixius discussed the landscaping issues and that the applicant must indicate whether this area
will be seeded or sodded. The plan also shows irrigation into a street right-of-way which would
need to be approved by the County and City Engineer. The applicant will also need additional
screening on the west edge of the parking lot and along the south edge of the drive-through lane.
Staff also recommends that the west parking lot pole be located in a raised curb island.
Brixius went on to show the plans of the proposed structure and to demonstrate the above
mentioned items to visualize.
Staff recommends approval of the site building plan upon the approval of conditional use permits
for the joint parking, the drive-through service lane and for the outdoor dining and the
comprehensive sign plan.
Commissioners showed concern with the traffic that occurs in the morning on CSAH 37 heading
towards I-94. Hudson wanted to note that there may be a future plan to put an entrance ramp to
I-94 off CSAH 19 which would help with the traffic.
Motioned by Klecker, seconded by Dominick to open the Public Hearing. Ayes: Klecker,
Dominick, Edgren, Barthel, and Wegner. Nays: None. Absent: Brempell. MOTIONED
DECLARED CARRIED.
Barbara Schneider, Border Foods, approached the podium to speak. She first addressed the cross
access easement; she said that they would not enter into this without a cross access agreement
with Donald and Anne Savitski. They are here today together to request approval of this project.
Schneider informed that Taco Bell has standards on the drive-through and how they work and
where the menu board is placed. When they need to snow plow they push to the perimeter, but
when needed they haul the snow off the premises. Schneider informed that they are agreeable to
an encroachment easement. The semi-trucks are eighteen wheel trucks and they receive two
deliveries a week and schedule those at off peak hours via a key drop system. Schneider noted
that they are looking to break ground in September and are looking to do a 90 day build.
Donald Savitski, owner of DJ’s Hardware, approached the podium. Mr. Savitski wanted to state
that during all of the years he has drove into DJ’s, he has not had any issues with the traffic to
turn into the site. Barthel expressed concern with the semi-trucks unloading and that they may
need to address it a different way. Mr. Savitski said that he does not believe there have been any
issues.
Planning Commission Meeting Minutes 6
Regular Meeting of June 14, 2016
Scott Dahlke, Civil Engineer, approached the podium. He wanted to address the raised curb
island vs. a striped island. He wanted to request that this still be a striped island due to snow
plowing and that may become difficult.
Donald Savitski, owner of DJ’s Hardware, approached the podium for a second time. He wanted
to offer that he is willing to add one handicap space if needed. He wanted to let the
commissioners know that he would like to stay with just the one stall because it never gets used.
Brixius informed Mr. Savitski that ADA requires more handicap stalls based on the number of
stalls there are.
Motioned by Barthel, seconded by Wegner to Close the Public Hearing. Ayes: Klecker,
Dominick, Edgren, Barthel, and Wegner. Nays: None. Absent: Brempell. MOTIONED
DECLARED CARRIED.
Staff recommends approval of the site building plan upon the approval of conditional use permits
for the joint parking, the drive-through service lane and for the outdoor dining and the
comprehensive sign plan based on the following conditions:
1. Joint Parking Conditional Use Permit
2. Loading Conditions
3. Drive-Through Conditional Use Permit
4. Pedestrian Connection Conditions
5. Outdoor Dining Conditional Use Permit
6. Lighting Conditions
7. Landscape Plans
8. Sign Plans
9. The City Engineer Comments
Motioned by Dominick, seconded by Edgren to approve the request by Taco Bell for Site and
Building Plan and Conditional Use Permits for Joint Parking, Drive-Through Service Lane,
and Outdoor Dining with the conditions outlined in the staff report . Ayes: Klecker, Dominick,
Edgren, Barthel, and Wegner. Nays: None. Absent: Brempell. MOTIONED DECLARED
CARRIED.
C. Public Hearing to Consider a Request by the City of Albertville for an
Amendment to the Albertville Zoning Ordinance Regarding Fees
Brixius stated that the City of Albertville processes all applications without consideration of
delinquencies on the property. Other cities have added a stipulation for the property owner to be
current on taxes before they can apply for an application.
Dominick had a concern that if someone was in a hardship and was delinquent, that this may
impair them from selling their property because they could not come in. He does not want to
make bigger hardship on someone.
Planning Commission Meeting Minutes 7
Regular Meeting of June 14, 2016
The draft ordinance includes language that prohibits an applicant, property owner, or tenant from
consideration of a new application when they have an outstanding debt to the City. This
ordinance update provides an opportunity by the City to ensure that properties requesting
services and approvals are not delinquent in their taxes or any outstanding fees.
Motioned by Barthel, seconded by Dominick to open the Public Hearing. Ayes: Klecker,
Dominick, Edgren, Barthel, and Wegner. Nays: None. Absent: Brempell. MOTIONED
DECLARED CARRIED.
No one wished to speak.
Motioned by Wegner, seconded by Dominick to close the Public Hearing. Ayes: Klecker,
Dominick, Edgren, Barthel, and Wegner. Nays: None. Absent: Brempell. MOTIONED
DECLARED CARRIED.
Motioned by Klecker, seconded by Wegner to approve the Request by the City of Albertville for
an Amendment to the Albertville Zoning Ordinance Regarding Fees. Ayes: Klecker, Edgren,
Barthel, and Wegner. Nays: Dominick. Absent: Brempell. MOTIONED DECLARED
CARRIED.
4. OTHER BUSINESS
A. None
5. ADJOURNMENT
Motioned by Barthel, seconded by Dominick, to adjourn the meeting at 8:22 p.m. Ayes:
Klecker, Dominick, Edgren, Barthel, and Wegner. Nays: None. Absent: Brempell. MOTION
DECLARED CARRIED.
Respectfully submitted,
___________________________________
Maeghan M. Becker, Building Permit Technician
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MEMORANDUM
TO: Adam Nafstad
FROM: Alan Brixius / Ryan Grittman
RE: Albertville - Temporary Family Health Care Facilities
DATE: July 7, 2016
FILE NO: 163.05 – 16.15
BACKGROUND
This Spring, the Legislature passed, and the Governor signed, a law purporting to
require municipalities to allow “temporary family health care dwellings” under MN
Statutes Section 462.3593. The new law defines these dwellings, requires their
accommodation, but includes an “opt-out” provision that permits the municipality to
exempt themselves from the provisions.
ANALYSIS
Intent of the New Law. The statute itself was developed and put forward by a New
Brighton firm called Next Door Housing that builds these units. The statute includes an
exemption for any municipality that already has an ordinance that allows temporary
health care dwellings as a permitted use. Cities that have a prohibition on RV
occupancy or other similar code are not immune to the law.
Components of the Statute. The new law includes the following aspects:
• Definitions of caregiver, person needing care, and “relative” providing care;
• Specifies that the subject of the Statute is a “mobile” residential dwelling;
• Specifies that the unit must be built off-site;
• Specifies that the unit is no more than 300 square feet, and has no permanent
foundation;
• That the unit is “universally” designed and meets accessibility standards;
• That the unit access plumbing and electrical through the principal home, or “other
comparable means”.
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• That the unit uses exterior materials compatible to “standard residential
construction” and has an energy rating of R-15;
• Is sized to be movable with a one-ton pickup truck;
• Provides that such units will be permitted uses;
• Provides for an application and permitting process, including notice to “adjacent”
property owners;
• Provides that the unit must meet setbacks and floor area ratio requirements;
• Provides that the unit is occupied by only one person;
• Provides for one six-month permit term, and one additional six-month term;
• Provides for municipal inspection and a revocation process;
• Provides for a maximum $100 fee for the initial permit, and $50 fee for the
additional term extension;
• Incorporates MN Statutes Section 15.99 for permit review.
• Provides for the opt-out ordinance as noted below.
Opt-out Provision. The new statute, as a part of MN Statutes 462 is incorporated into
the municipal planning and zoning regulations, and will become effective on September
1, 2016. The municipality will have to opt-out of the regulation prior to that date to avoid
its effect. Because this is a zoning regulation, any opt-out will need to be processed as
an amendment to the Zoning Ordinance, requiring the typical hearing and ordinance
adoption. The only opt-out is an explicit opt-out.
Accessory Dwelling Units Generally. The issue of accessory dwelling units for the
purpose of providing living space for family members needing care has been widely
discussed. The context for most of these discussions has been for attached units that
constitute some form of second dwelling on single family parcels. There are various
arguments, pro and con, for these units.
Issues Under the New Law. Apart from the issues raised by accessory dwellings, the
temporary family health care dwelling addresses a separate aspect of this issue –
mobile, detached “trailer” units that are hauled to the subject residential property,
installed with connections to the electrical and plumbing services from the main house,
and then detached and removed, theoretically, when their use is no longer needed.
Interestingly, the statute provides for a single six-month period of installation, and the
option for one additional six-month period. The statute also provides for an extensive
process of permitting and locational regulations that would supersede a community’s
normal review process. It is not clear how the statute might apply to somebody who
wishes to apply for a third six-month period – it would appear that the statute prohibits
that extension.
The statute also allows for one unit per lot without distinguishing between single family
or multiple family properties (twinhome, townhome). The statute allows only one person
to reside in the unit.
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In the City of Albertville, some of the residential neighborhoods consisting of small to
mid-sized lots raise question with regard to rear yard access and unit placement.
Placement of a temporary health care unit is required to meet principal building
setbacks. This will be problematic on the smaller lots in the City.
SUMMARY AND ALTERNATIVES
1. The municipality may choose to do nothing, and allow the statute to go into
effect. In this case, all of the details of the law, including size, location,
construction, delivery, timing, and process would be regulated by the statute.
2. The municipality may decide that it wishes to allow temporary family health care
dwellings, but prefer ordinance details more tuned to its specific requirements
and zoning objectives. Examples of alternatives preferred by the municipality
might be providing for site-built facilities, differences in size or materials,
differences in location or screening requirements, the use of interim use permits
or conditional use permits, or alternative notice requirements, just to name a few.
In such a case, the municipality should take action to adopt an ordinance opting-
out of the statute, and proceed to adopt its own regulations. It will be important
that the municipality opt-out of the State law, or the statute may have the effect of
pre-empting the preferred alternative.
3. The municipality may decide that only attached accessory units are suitable in
their community. Again, the municipality will need to take specific action to adopt
an opt-out ordinance to avoid the effect of MN Statutes 462.3953 prior to
September 1, 2016.
4. The municipality may decide that it does not favor accessory units. Instead,
families who are considering providing health care to their family members can
do so within the confines of a single family home. It may be necessary to add
some definition to what constitutes a separate residential use (especially cooking
and sanitation/plumbing facilities) to ensure that single family homes are not
accidentally modified to create additional dwelling units on the property.
RECOMMENDATION
While the City has a number of options for addressing this issue, staff would strongly
recommend that the City adopt the attached ordinance to opt-out of the State
regulations to avoid land use and performance standards issues that will occur with the
application of State standards on lots within Albertville. If the City believes that this
housing option is needed within the City, the City will adopt its own regulations specific
to the City and appropriate for its lot sizes and neighborhoods.
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c: Kim Olson
Meaghan Becker
Mike Couri
Paul Heins
Attachments:
Exhibit A Opt-out Ordinance
Exhibit B Photos
12 EXHIBIT A
CITY OF ALBERTVILLE
COUNTY OF WRIGHT
STATE OF MINNESOTA
ORDINANCE NO. 2016 – ___
AN ORDINANCE AMENDING SECTION 100 OF THE ALBERTVILLE ZONING
CODE RELATING TO TEMPORARY HEALTH CARE UNITS
WHEREAS, on May 12, 2016, Governor Dayton signed into law the creation and regulation of
temporary family health care dwellings, codified at Minn. Stat. § 462.3593, which permit and
regulate temporary family health care dwellings.
WHEREAS, subdivision 9 of Minn. Stat. §462.3593 allows cities to “opt out” of those
regulations.
THE CITY COUNCIL OF THE CITY OF ALBERTVILLE, MINNESOTA HEREBY
ORDAINS:
Section 1. Section 100 of the Albertville City Code is hereby added as follows:
Section 100.11: OPT-OUT OF MINNESOTA STATUTES, SECTION 462.3593: 1000.24.
Pursuant to authority granted by Minnesota Statutes, Section 462.3593, subdivision 9, the City of
Albertville opts-out of the requirements of Minn. Stat. §462.3593, which defines and regulates
Temporary Family Health Care Dwellings.
Section 2. This ordinance shall be effective upon its passage and publication.
Approved by the Albertville City Council this _____ day of ______ 2016.
Jillian Hendrickson, Mayor
ATTEST:
Kimberly A. Olson, City Clerk
EXHIBIT B13
EXHIBIT B14
BASICS OF PLANNING
Michael C. Couri
Couri & Ruppe, P.L.L.P.
Attorney at Law
AUTHORITY FOR LAND USE REGULATION
Case Law.
• Authorized by “police power” per U.S. Supreme Court in 1926.
Police powers are powers that protect the public health, safety
or welfare.
• Regulation amounts to a regulatory taking of the property
when owner is denied all economically viable use of the
property.
Statutory basis for zoning.
• Minn. Stat. Ch. 394 (counties).
• Minn. Stat. §§ 462.351 – 462.365 (cities and towns).
• The police power is inherent in the State, not local
government.
• The only power local governments have is that delegated to
them by the State.
AUTHORITY FOR LAND USE REGULATION
Statutory limits on zoning authority.
• Specific standards set out in statutes for:
o Variances.
o Conditional Use Permits
o Interim Use Permits
o Nonconforming Uses
• A state-licensed group home of six or fewer is automatically a
permitted single-family residential use.
• A state-licensed group home of 7-16 is a permitted
multifamily residential use that can be subject to a CUP.
CONSTITUTIONAL LIMITS
Regulations must be uniformly applied. This is what is referred
to as equal protection under the law. This means:
• Similarly situated landowners must be treated the same.
• Similarly situated refers to not only circumstances, but time.
• When an equal protection challenge is asserted, the
municipality must offer a legitimate reason for distinction.
Governmental action must be “reasonable” and to accomplish a
legitimate public purpose.
• This limitation on governmental action is often referred to as
“substantive due process.”
• Substantive due process requires an egregious set of facts to
support a claim.
CONSTITUTIONAL LIMITS
The governmental process must be “fair.”
• This is known as procedural due process.
• Fairness does not include a right to cross-examine witnesses
opposed to a particular permit application.
• Fairness = notice of the process and an opportunity to be
heard.
CONSTITUTIONAL LIMITS
Takings (Eminent Domain)
• Takings claims are based upon the constitutional
prohibition against a government taking property
without paying just compensation to the owner.
• Claims are that regulations amount to a taking of property.
•Basically, a regulation cannot deny all economically viable use
of land.
• These claims are often decided based on the
circumstances of each case.
CONSTITUTIONAL LIMITS
Exactions
• Exactions, generally, are when a government conditions its
approval of a land use application on the owner performing a
certain action or granting the government some benefit or
property right.
• There must be an “essential nexus” between the condition
imposed and the burden the proposed land use would cause.
• If the government requires the dedication of land or an
easement, the government must prove a “rough proportionality”
between land required and impact of development.
• State law specifically allows for certain exactions or
dedications for things such as public streets, parks, utilities, and
storm water drainage.
DO NOT ADVOCATE
•When processing a zoning application, you cannot
advocate a position until all information has been
submitted.
•Do not declare a position on the issue before the
item is properly before your board.
•Do not sign petitions or campaign in favor or against
an issue that is the subject of a zoning application.
•Courts will invalidate board decision if a board
member has declared a position before record is
complete.
MORATORIA AND INTERIM ZONING
A temporary development or rezoning freeze while a municipality
considers the adoption or amendment of official controls and/or
comprehensive plans.
To adopt a moratorium a municipality must make a finding that
it:
• is conducting studies to consider the adoption or amendment
of a comprehensive plan or a zoning ordinance; or
• has authorized a study to be conducted regarding the
adoption or amendment of a comprehensive plan or zoning
control ordinance; or
• has held or has scheduled a hearing for the purpose of
adopting or amending a comprehensive guide plan or zoning
ordinance; or
• has annexed new territory for which there are no existing
plans or controls.
MORATORIA AND INTERIM ZONING
Generally, no special public notice is required before an
interim ordinance is considered or adopted by a town or city.
The initial interim ordinance lasts for up to one year from the
date it became effective.
• Can be extended for the following reasons, but in no event
longer than an additional 18 months:
o for up to an additional 120 days from the receipt of a
federal, state, or metropolitan approval;
o for up to an additional 120 days from the completion of
any other process required by state or federal law;
o for up to 1 year if the city or town hasn’t adopted a
comprehensive plan at the time the moratorium is enacted.
MORATORIA AND INTERIM ZONING
No interim ordinance can affect a subdivision that has been given
preliminary approval.
Moratorium adopted after application submitted may or may not
be valid—depends on the facts. Generally, must be enacted to
protect the planning process, not to halt a specific proposal.
THE 60-DAY RULE
Minn. Stat. § 15.99 requires written requests relating to zoning,
septic systems and/or the expansion of MUSA to be approved or
denied within 60 days from the date of application.
• A failure to deny a request within the time frame is an
automatic approval of the request. But only to the extent that
the town, city or county has authority to grant such request.
• The municipality can show that it met the time requirement if
it can document that its decision was sent within 60 days after
receipt of the written application.
THE 60-DAY RULE
The 60-day period can be extended for 60 more days if the
municipality provides written notice to the applicant, prior to the
expiration of the deadline, stating the reasons for the extension, and
stating it’s length.
• Oral notice of an extension is not sufficient.
• The applicant may request an extension of the time limit by
written notice that is “explicit and definite.”
THE 60-DAY RULE
An incomplete application can stop the running of the 60-day
period if the municipality sends notice within 15 business days of
receipt of the request telling the applicant what is missing.
• 60-day period remains tolled until missing information is
provided and application is complete.
o Application must be on agency’s form, if one exists.
o Completeness under the 60-day rule can only be
determined by reference to a pre-existing rule, ordinance or
policy.
o When an applicant makes an amendment to its request
that is “material or significant,” the 60-day period begins
anew and runs from the amendment.
THE 60-DAY RULE
The time period is tolled if the requested action requires the prior
approval of a state or federal agency. 60 days begins to run when
the required approval or process has been completed.
• Example: EAW or EIS.
THE 60-DAY RULE
Must send written notice of denial with reasons for denial within
60 days otherwise request is automatically approved.
• A rejection of a motion to approve constitutes a denial if those
voting against approval “state on the record the reasons why
they oppose the request.”
The 60 day rule does not apply to subdivision requests submitted
to a town or city. There is a separate 120 day limit for city approval
of subdivisions. Chapter 505 does not have a time limit for Counties
to approve subdivisions.
The 60-day rule does not apply to a building permit request.
THE RECORD
The Public Hearing
• All meetings considering request must be open under the
Open Meeting Law
o The Open Meeting Law applies to City Council, Township
Board, County Board, Planning Commission and Board of
Adjustment meetings.
o Presence of a quorum of a body discussing public
business constitutes a “meeting” under the Open Meeting
Law.
o Informal site visits, where a quorum of the body is
present, can result in Open Meeting Law violations. Give
notice of such visits.
THE RECORD
The Public Hearing
• Pre -hearing Notice Requirements
o Minn. Stat. § 394.26 (counties) and Minn. Stat. § 462.357,
Subd. 3 (towns/cities) set forth the notice requirements for
public hearings involving conditional use permits and
variances.
o Law requires notice of the general purpose of the hearing,
but does not require that the details of the proposal be
disclosed.
THE RECORD
• Procedural Due Process
o Under state and federal law the right to due process
means the right to notice and an opportunity to be heard.
o The right to procedural due process does not normally
include the right to cross examine witnesses.
o The right to procedural due process can be analogized to
a right to a fundamentally fair process.
THE RECORD
• Conduct of the Hearing
o Remember that every application considered and denied
could become a lawsuit.
o At the hearing allow an applicant to inspect documents,
present evidence, and fully present the case.
Establish rules of procedure as necessary to maintain
control of the hearing, provide for appropriate public
input under the circumstances, and keep the length of
hearings reasonable.
THE RECORD
•Conduct of the Hearing
o The applicant has the burden to present evidence to show
he or she meets the requirements of the ordinance for the
permit required.
o Make a record of the basis for denial or approval.
o Make all pertinent documents part of record of the
proceedings.
o Listen to public sentiment and opposition, but do not let it
drive your decision. Respond appropriately to facts
presented.
o Any exhibits (documents, photographs) presented should
be made a part of the record.
o Do not stretch the terms of your ordinance to justify the
granting or denial of a permit.
THE RECORD
Findings/the Decision
• Findings of fact are necessary as part of a permit denial or
approval.
• Findings of fact should constitute an exercise of application of
the record evidence to the standards set forth in the ordinance.
• Findings of fact should use the applicable decisional standards.
•Findings of Fact need to be contemporaneous with the decision
and must be based on the record.
o Findings prepared within a reasonable amount of time from
the zoning decision and based on reasons given when motion
was approved are OK if a full record exists.
THE RECORD
• Making the Record
o In almost all cases, an adequate record precludes the
applicant from introducing new data during an appeal of the
municipality’s decision.
o During judicial review, a court will review the “record”,
and determine whether the decision of the Board or Council
was reasonable in light of record evidence.
oTape record or video the public hearing so that a
permanent verbatim record of the proceedings is available if
the issue goes to court.
THE RECORD
•Importance of the Record
o The standard of judicial review in all zoning matters is
whether the zoning authority’s action was reasonable (is the
decision reasonably supported by the evidence in the
record?)
o Great deference is given to the decisions of municipalities
in zoning matters, such that the role of the judiciary is limited
and sparingly invoked.
o Court will not substitute its judgment for that of the
municipality.
o If the record is not good, the Court will likely allow the
record to be supplemented with testimony at a trial. This will
get ugly—depositions, discovery, GREAT EXPENSE!
CONFLICTS OF INTEREST
Common Law Conflict of Interest
• Direct Pecuniary Interest Prohibited. Under common law, a
public official is disqualified from voting on a matter if the official
has a “direct” financial interest in the outcome of the matter.
o Purpose. The purpose of this rule is to ensure that a
decision will not be an arbitrary reflection of an official’s own
financial interests.
CONFLICTS OF INTEREST
Common Law Conflict of Interest.
•Curing a Common Law Conflict.
o A common law conflict of interest may be cured by
abstaining from the vote.
• Validity of Action. An action taken may be valid if the vote of
the disqualified official did not affect the outcome of the
decision.
Even when a conflict of interest does not exist, the “appearance”
of a conflict has the potential to tarnish the decision-making
process.
Variances
What is a Variance?
•Official permission to use your property in a
way otherwise prohibited by the zoning
ordinance.
•Most common with setback issues—not
enough room to set the house back from
the road or the lake.
•Landowner must apply for an receive a
variance from the City after a public
hearing.
2011 Legislative Amendment
•The variance may be granted if:
–There are “practical difficulties” in complying with the
zoning ordinance.
–The variance will not alter the essential
character of the locality.
–Circumstances unique to the property not caused by
the landowner or his predecessor.
•Also requires that the variance be:
–In harmony with the general purposes and intent of
the zoning ordinance.
–Consistent with Comprehensive Plan.
What are “Practical Difficulties”?
•Defined in statute as the “property owner
proposes to use the property in a reasonable
manner not permitted by the zoning
ordinance.”
•No guidance as to what is a “reasonable
manner.”
•Likely means at least one of the following:
–Proposed use is similar to existing uses in
the neighborhood.
–Proposed use is permitted in other
zoning districts elsewhere in the town.
–Has few, if any, adverse impacts on other
properties.
•Courts will have to decide just what this
means.
Conditions
•City can also put conditions on the
variance, but they must be “directly related
to” and “roughly proportionate” to the
impact created by the variance.
Net Impact •Variances may be harder to deny?
–“Undue hardship” standard is gone.
–Under previous standard, courts gave great
deference to local government decision on
variances—Cities were rarely reversed.
–Courts may give less discretion to local
governments under new standard given explicit
“reasonable manner” standard.
–Cities should be careful to develop detailed
findings of fact to support a variance denial
decision.
What is a Conditional Use Permit
(CUP)?
•Permitted use, provided applicant meets the
qualifications and conditions imposed by
ordinance and Town Board.
•Allows greater control over uses that may
conflict with neighboring properties or
generate traffic, noise, or other problems.
•Once granted, it runs with the land and can
stay forever as long as conditions are not
violated—no set termination date.
•Can be revoked after a hearing if conditions
are violated.
•Once issued, conditions cannot be modified
except with the agreement of the property
owner.
Processing a CUP Application
•The applicant must meet all general
conditions contained in the CUP section of the
Town’s zoning ordinance.
•The applicant must meet all specific
conditions contained in the zoning district
which authorizes the CUP.
Imposing Conditions
•Township can impose conditions in the CUP
permit.
•Conditions must be related to the impacts
created by the proposed CUP.
•Cannot require that a legal non-conforming
use be terminated—that is a taking requiring
compensation.
•Town does not need the applicant’s consent to
impose a condition.
Quasi-Judicial Hearing
•Planning Commission/Town Board sits in a quasi-
judicial capacity when processing a CUP.
•Must determine whether applicant meets the
criteria contained in the ordinance.
•If criteria met, CUP must be issued, but can
contain conditions imposed by Town.
•Decision must be based on the facts in the
record.
What is an Interim Use Permit
(IUP)?
•Very similar to a CUP, except
that it is issued for a limited
period of time.
•Can end on a date certain or an
event. Examples:
–IUP for a gravel pit may
permit extraction of 50,000
cubic yards before it
terminates.
•Examples (Continued)
–IUP for a second home on a property to
care for elderly parents may terminate
when parents no longer live in the
second home.
–IUP for farmers’ market expires on
November 15, 2015.
•May be renewed upon expiration with the
same or new conditions as determined by
the Town Board.
Caution!
•Minnesota Statutes require that the user
agree to the conditions imposed on the
applicant in granting the IUP.
•The law is unclear as to what happens if the
applicant disagrees with conditions imposed
by the zoning authority.
Why use an IUP?
•Allows for more control over potentially
conflicting uses.
•Allows a use now that may not be
appropriate at that location in the future.
•Gives the Town a chance to impose
additional conditions if conflicts arise.
•Maximizes the
productivity of property
by allowing temporary
uses that would
otherwise not be allowed
as a CUP.
How do you implement an IUP?
•Establish an IUP section in your zoning
ordinance, similar to the existing CUP general
conditions section.
•Review each zoning district to see what
permitted and conditional uses should be
changed to IUPs.
•Define the IUP uses within each zoning district
and set out any specific conditions.
How do you administer an IUP?
•They are treated very similar to CUPs.
•Applicant needs to apply for an IUP.
•Must hold a public hearing after due notice.
•Need findings of fact to approve or deny.
•Decision can be appealed to District Court.
•Final approval should be recorded at
County Recorder’s office.
•Copies of IUPs should be kept in a separate book
so that they can be reviewed to make sure they
do not last longer than allowed.
THANK YOU!
END OF LEGAL PRESENTATION
OFFICIAL ROLES AND RESPONSIBILITIES
Staff
Planning Commission
City Council
STAFF ROLES
Administer the planning process
Initial contact with applicants and developers, outline zoning requirements and
application process
Prepare planning reports consistent with Comprehensive Plan, compliant with Zoning and
Subdivision Regulations, and infrastructure needs
Formal presentations of application to Planning Commission, City Council, and public
Technical advice to the Planning Commission, City Council and public
Enforcement
PLANNING COMMISSION ROLE
Participation in the preparation of the City’s Long Range Comprehensive Plan. Establish the vision, goals and priorities for future land use, growth, and infrastructure.
Serve as the advisory body on development applications, variances, conditional uses, site plan reviews, and planned unit developments.
Review and make recommendations on:
•Comprehensive Plan Amendments
•Zoning Map Amendments (Rezoning)
•Zoning Text Amendments
•Conditional Use Permits
•Interim Use Permits
•Variances
•Planned Unit Developments
•Subdivisions
PLANNING COMMISSION ROLE (Continued)
Planning Commission review and recommendation:
•Comprehensive Plan consistency
•Compliance with technical standards of Zoning and/or
Subdivision Regulations
•Outline findings for decisions
PLANNING COMMISSION ROLE (Continued)
The Planning Commission is an advisory body to the City Council and charged with the responsibility of researching, reviewing, and making recommendations on issues related to City planning, land use, and development in the City.
Big Picture –Comprehensive Plan –Blueprint for the City guiding land use, transportation, utilities
Goals and policies establish the City’s vision, defines neighborhoods, establishes priorities and quality of development.
The Planning Commission role is to understand the big picture, serve as an advisory board to the City Council, ensure that each development request is consistent with the vision of the City and compliant with the City performance standards.
The Planning Commission has been integral in the comprehensive planning process in establishing realistic expectations and goals for the City.
The Planning Commission serves as an advisory body to the City Council and must work closely with City staff to present a consistent front for dealing with development requests.
CITY COUNCIL ROLE
Sole legal authority of the local government
Authority to adopt a Comprehensive Plan
Authority to adopt local codes and ordinances
Controls the City budget
The final forum for action on approval or denial of development
applications
EFFECTIVE MEETINGS / PUBLIC HEARINGS
Agenda
The agenda outlines the meeting topics for discussion. The Planning Commission may amend the
agenda to add discussion topics. Once the agenda is approved, follow the agenda.
Staff Presentation of Agenda Topic or Development Application
The staff presentation is an evaluation of the development application against the City’s
established development regulations (zoning, subdivision, etc.).
Public Hearings
Chair opens public hearings and requests public comments within the following format:
i.Public comments must germane to the issue.
ii.Speakers must address their comments and questions to the Chair and Commission, not to the applicant or other individuals at the meeting.
iii.Speakers are directed to focus on new information relevant to the issue and avoid repetitive comments.
iv.Audience must not interrupt the speaker with comments, applause, or other disruptions.
v.Speakers must identify themselves by name and address, including representation of any interested party.
vi.Speakers must speak from the microphone/podium to ensure that they are heard by Commission members, recording equipment, and those observing the meeting electronically.
vii.Planning Commission members may ask questions of speakers while they are at the podium.
viii.Answers to speakers’ questions are typically held until all speakers have been heard. This rule is often modified to avoid many speakers asking identical questions.
ix.Speaker testimony is taken as called on by the Chair. With controversial issues that attract larger public attendance, the City may require speakers to sign in to speak or may limit the time of each speaker to ensure more people have the opportunity to express their opinions.
At the end of the public testimony, the Chair may close the public hearing. If the application or item requires additional r esearch or review to be held over to another Planning Commission meeting, the public hearing may be continued to a future date to allow public comment on new information prior to Planning Commission action.
Public Hearings (Continued)
Discussion
Once the hearing is closed, the Chair invites members to discuss the issue. The purpose of discussion is to ensure that adequate information has been gathered to formulate a motion. The Commission may ask staff, applicant, or members of the public for clarification of specific points.
Decision –Approval, Denial or Continuation
•Motion and second –recommendation to the City Council
•Staff report offers findings and recommendation basis for decision. Findings are critical for any decision for protection against a challenge to the City’s decision.
•If the application is tabled, the Planning Commission must be aware of any 60 day rule issues relating to the amount of time for a decision.
•Motions on zoning recommendations are carried with a simple majority of the members present.
i.If a motion to deny or approve fails to receive a simple majority (either gains only a minority or ends in a tie vote), the Chair should declare that the motion fails, and ask those who voted against the motion to state their reasons on the record. Under this scenario, the item goes to the City Council without a recommendation from Planning Commission, with the stated reasons servings as the “findings”.
ii.In the alternative, a member may make a substitute motion and the Commission may consider it separately .
UNDERSTANDING MANAGING CITIZEN
OPPOSITION
Community residents think of themselves as customers rather than
citizens
NIMBYS, organized neighborhoods armed to obstruct development
Minnesota Environmental Review Programs (EIS, EAW, AUAR) used to
obstruct, delay, and add expense to projects
UNDERSTANDING MANAGING CITIZEN OPPOSITION (Continued)
Managing citizen opposition:
•Define meeting format, presentation and public comment at the beginning of a meeting
•Direct all comments and questions to the Planning Commission not to the applicant
•Avoid interruptions of speakers, applause, shouting, or other disruptions
•Require all speakers to identify themselves
•Hold questions until the end of the speaker
•Allow staff to address technical questions
•In taking action on any project, explain the basis for decision through findings. Use the staff report for the findings
CONSIDERATIONS
Defined City goals and policies –clearly communicated
•Comprehensive Plan
•Zoning Standards
•Subdivision Requirements
Developers are investing in Albertville and they have choices when it comes to when and where they make their investment decisions
Some public comments have merit in the consideration of a project and may be included in the Planning Commission decision
Communities have reputations within the development industries. Which cities are good to work with and which cities are difficult?
•Customer service, good communication, timely service, predictable outcomes
•Clear and understandable regulations. If we address these standards, we may anticipate a successful outcome
•Will the review process accommodate the developer’s project schedule?