Letters to the Editor

Our goal is to offer readers diverse perspectives on newsworthy events or issues of broad public concern to the Hill & Lake community.

Multiplexes Coming to a Lot Near You

Many neighbors were shocked to find out that the new zoning regulations adopted in conjunction with the 2040 plan allow historic single family, duplex and triplex homes in many parts of the city to be torn down and replaced with box-like multiplexes, effectively ruining the character and fabric of our neighborhoods. The city’s response is that multiplexes are part of the 2040 Plan adopted in 2019, so no one should be surprised. The truth is that many (if not most) are, in fact, very surprised.

The 2040 Plan seemed to allow triplexes and only contemplate multiplexes as an exception to be built on the few “larger lots” that could accommodate them best. What is hard to understand is that what the city considers a “larger” lot has decreased in size several times so that many, if not most, of the lots in our neighborhood qualify as “larger lots” and are therefore eligible for large multiplex buildings with all of the issues that such large buildings entail. In fact, there are nearly 3,500 such lots. It looks as if the exception has become much more the rule.

At the same time, the city also removed the limit on the number of units that can be built on a larger lot. On slightly larger lots, six, eight, ten or more units are now allowed. The changes affect 3500 lots in historic neighborhoods in our city and were adopted by the city with little public debate.

These changes were not in the 2040 Plan, but are changes the city is now proposing, claiming that they are nothing new. They are new. The lot size for a “larger lot” should never have been decreased to equal the size of almost half the lots in our neighborhoods and the city is not compelled to eliminate ratios limiting the number of units per lot for multiplexes. For example, triplexes are effectively required to have only 2,000 SF per unit. If you care about preserving the character of our neighborhoods and think the city should rethink these changes, please voice your opinion before March 26.

Karin Birkeland, Lowry Hill

Taken Aback by February 2040 Plan Editorial

I'm a renter in the East Isles neighborhood and I've lived here for almost two years after moving to Minnesota upon graduating from St. Olaf College.

I was excited to receive the Hill & Lake Press the other day, however the front page editorial co-written by you (Craig Wilson) and Marty Carlson was quite a shock for me. I'm a bright-eyed recent grad who is intrigued by urban planning and has eyes on the Humphrey School, and admittedly am still learning the history of the Twin Cities' urban design (I see you have a Master's of Urban and Regional Planning degree). However, I was taken aback by some of the arguments in the article. I didn't see anywhere online to have a conversation with other readers, so I figured I'd email you, the newspaper editor and writer of this article, with my questions and reactions. I'd love it if you took the time to read and respond.

I think that the existing apartment complexes on Humboldt especially are a testament to the city's ability to build multi-unit housing that matches the design of the neighborhood. The beautiful brownstone buildings compliment the large single-family homes in these neighborhoods. Who says that new 4-plexes will not be able to be developed with a similar design?

Awesome that about half of the rental properties are under the affordable threshold. Why, then, prevent more affordable housing from being built in this gorgeous neighborhood? What is the worry with making housing available to a larger audience? That it won't visually match the vibe? I'm having trouble understanding that argument.

"Our complaint is that the proposed zoning plan... treats the city as a featureless slate on which zoning is wielded as a blunt and indiscriminate instrument, implemented with little consideration of the historic and existing character of individual neighborhoods." What is the historic and existing character of East Isles? I didn't know that these neighborhoods were a historic district when I moved here or since living here the past two years, and after looking it up it looks like there's only a small portion of the three of these neighborhoods that is actually considered historic. You made it seem like the entirety of the neighborhoods should not be zoned in this way because of their "historic nature."

Really, I'm just afraid of what the new version of redlining will be for Minneapolis-St. Paul. I fear the transition from discriminating against race (such as destroying the Rondo neighborhood with the construction of I-94) to discriminating against class (which, inextricably tied to race, is really the same thing) by preventing affordable housing to be built in certain neighborhoods. I admit to not knowing all the intricacies behind how affordable housing is ensured in a given zoning district, however I'd hope that our City's urban planners could figure that out.

I look forward to participating in more East Isles activities to make sure my voice is heard, as I'd love to hold conversation over these ideas with others in the area.

Kiernan Bartlett, East Isles

And Now a Word from the City of Minneapolis Pedestrian Advisory Committee

This just in from the Minneapolis Pedestrian Advisory Committee regarding the latest version of the Cedar-Isles Park Board Plan:

"The Pedestrian Advisory Committee (PAC) supports many aspects of the Plan for Cedar Lake and Lake of the Isles and believes that an improved design remains possible… Before addressing the design elements of the plan, it is imperative to address a community engagement process that permits those with wealth and privilege to perpetuate a destructive, collapsing status quo and to demand that they control public land regardless of public good."

That’s a direct quote, emphasis ours. The PAC Resolution also stresses the importance of having vending machines at every park “welcome point.” You can read the full document, which appears on City of Minneapolis letterhead, by contacting 311 or visiting the City's website.

Lori Mittag, Kenwood

I continue to love this paper!

Most of the articles contain common sense thinking regarding the redo of Hennepin Ave., Lake of the Isles and Cedar plans, the bike lobby and the 2040 plan. Thank you Craig Wilson, Marty Carlson, Susan Lenfestey, Mary Pattock and Carol Becker for making your articles so clear and informative.

Roselyn Rezac, Bryn Mawr

Feedback on 2040 Plan Editorial

Your most recent article regarding Minneapolis 2040 is full of factual errors. The most obvious being that Minneapolis 2040 built form regulations went into effect January 1, 2021, and so the Interior 2 designation is not new. UN2 designation is not up-zoning, its simply the land use zoning district associated with the previously applied Interior 2 built form zoning district.

Tyler Richards, Kenwood

The City's Planning Department sent this unusually long Letter to the Editor that exceeds our normal copy limit. We decided to run it in full as an exception.

City Response to Last Month's Editorial about the 2040 Plan

Minneapolis adopted its 2040 Comprehensive Plan (Minneapolis 2040) which went into effect in January 2020. The Plan identifies high level goals and a vision for the future of Minneapolis, including the built form and land use guidance. Among other things, a city’s comprehensive plan enacts future land use guidance, which provides a general vision for the future development of all parcels within a city. In the case of Minneapolis 2040, the plan broke the future land use guidance into two sections and adopted two separate but inter-related maps, the Future Land Use Map and the Built Form Map. https://minneapolis2040.com/topics/land-use-builtform/

Minneapolis 2040 created 12 new future land use categories. The Future Land Use Map guides the types of uses allowed on a given parcel according to each category. The Built Form Map guides the scale of development for every parcel in the city, independent of the uses allowed on the site. The built form of all new and remodeled buildings must be consistent with the guidance of the Built Form Map. There are 14 Built Form designations. The Built Form Map works in tandem with the Future Land Use Map to provide a complete set of guidance for each parcel.

The residential areas around Cedar Lake and Lake of the Isles have a Future Land Use guidance of Urban Neighborhood. The Urban Neighborhood Future Land Use designation is assigned to the vast majority of residential properties throughout the City.

1. Urban Neighborhood – A predominantly residential area with a range of allowed building types. May include small-scale institutional and semi-public uses (for example, schools, community centers, religious institutions, public safety facilities, etc.) scattered throughout. Like the Neighborhood Mixed Use category, commercial uses can continue serving their existing commercial function. Commercial zoning is appropriate for these properties, while expansion of commercial uses and zoning into surrounding areas is not encouraged.

The residential areas around Cedar Lake and Lake of the Isles have a Built Form designation of either Interior 1 or Interior 2.

1. Interior 1 – The Interior 1 district is typically applied in parts of the city farthest from downtown, in the areas between transit routes. Built Form Guidance: New and remodeled buildings in the Interior 1 district should be small-scale residential. Individual lots are permitted to have up to three dwelling units. Combining of lots is generally not permitted. Building heights should be 1 to 2.5 stories.
2. Interior 2 – The Interior 2 district is typically applied in parts of the city that developed during the era when streetcars were a primary mode of transportation, in the areas in between transit routes, and on select streets with intermittent local transit service. It is also applied adjacent to the Corridor 4 and Corridor 6 districts, serving as a transition to lower intensity residential areas. Built Form Guidance: New and remodeled buildings in the Interior 2 district should be small-scale residential. Individual lots are permitted to have up to three dwelling units. Multifamily buildings with more than three units are permitted on larger lots. Limited combining of lots is permitted. Building heights should be 1 to 2.5 stories.Changing the boundaries of the Built Form designations would require a comprehensive plan amendment.

Adopted Form Overlay Districts.

Because the Minneapolis Plan created all new future land use categories, and introduced built form designations, it required a complete rewrite of the City’s zoning code. A zoning code is a tool which implements a city’s comprehensive plan and regulates the land use and built form of every parcel in the City. State statute requires cities to update their zoning to comply with their adopted comprehensive plans within 9 months of their adoption (https://www.revisor.mn.gov/statutes/cite/473.865).

In order to align the zoning code with Minneapolis 2040, it was necessary to break the code into two sections, one which would regulate land use and the other which would regulate the built form. The built form regulations were completed first and went into effect in January 2021. Because the underlying zoning districts were not updated yet to align with the future land use categories in Minneapolis 2040, the built form regulations were adopted as overlay districts that would apply over the top of the existing zoning districts. The Built Form Overlay Districts regulate the physical form of structures on a given parcel, such as height, floor area ratio, and setbacks. They also regulate the minimum lot area for certain types of development, as well as place limits on the combining of lots for each Overlay District. There are 14 Built Form Overlay Districts, which correspond to the 14 Built Form Designations in Minneapolis 2040:

1. An overview of the Built Form Overlay Districts and the adopted map can be found here: https://minneapolis2040.com/implementation/built-form-regulations/
2. The Built Form Overlay District Handbook, which includes all of the regulations can be found here: https://minneapolis2040.com/media/1818/ver3_cityofminneapolis_built-form-overlaydistricts-handbook.pdf

The Interior 2 Built Form Overlay District (BFI2) applies to properties with an Interior 2 Built Form guidance in Minneapolis 2040:

1. The full ordinance can be found here: https://library.municode.com/mn/minneapolis/codes/code_of_ordinances?nodeId=MICOOR_TIT20ZOCO_CH552BUFOOVDI
2. A handout that summarizes the regulations for Interior 2 can be found here: https://minneapolis2040.com/media/1723/cityofminneapolis_built-formoverlay-districts-handbook_interior-2.pdf

Bottom Line: Given that Interior 2 future land use is clearly supposed to accommodate buildings with 4+ units on larger lots, adopting zoning regulations that don’t allow 4+ unit buildings is not a reasonable outcome. That would leave us with an overt conflict between adopted policies and regulations.

Adopted Built Form Regulations:

1. Adopted Maximum Floor Area Ratio:A) The maximum floor area ratio for 1-3 unit buildings in the BFI2 Overlay District is 0.5;B) The maximum Floor area ratio for 4+ unit buildings in the BFI2 Overlay District is 0.8
2. Adopted Minimum and Maximum Lot Dimensions. Below are the lot dimension regulations that apply to buildings with 4+ dwelling units in the BFI2 Overlay District:A) Minimum lot width of 50 feet;B) Minimum lot area of 7,500 square feet;C) Maximum lot area of 14,000 square feet
3. Adopted Building Height. Below are all of the height regulations that apply to buildings in the BFI2 Overlay District:A) Dwellings with 1-3 units and cluster developments: i) 2.5 stories, 28 ft. and the highest point of a gable, hip, or gambrel roof shall not exceed 33 feet: Notwithstanding the height limitations of this chapter, the maximum height of single-, two-, and three-family dwellings may be increased to thirty-five (35) feet when the established height of a minimum of fifty (50) percent of the single-, two-, and three-family dwellings within one hundred (100) feet of the subject site exceed the maximum height. The highest point of a gable, hip, or gambrel roof shall not exceed forty (40) feet; ii) Additional exemptions allowed administratively: Rooftop features used exclusively for mechanical equipment, elevators, or stairways on single-, two-, or three-family dwellings, provided all of the following conditions are met: a) Such building features may extend up to ten (10) feet above the roof of the floor below; b) The combined coverage of such building features shall not occupy more than one hundred fifty (150) square feet of the roof area. c) Other height increases: by variance only.B) Institutional and civic uses: i) 3 stories, 42 ft; ii) Exemptions allowed administratively: see below for all other uses: iii) Height increases: by variance only.C) All other uses:A) 2.5 stories, 35 ft.;B) Exemptions allowed*: i) Communication antennas, wind energy conversion systems, and solar energy systems otherwise allowed by administrative review in Chapter 550, Development Standards; ii) Parapets not exceeding three (3) feet, except where located on single-, two-, or three-family dwellings or cluster developments; iii) Railings up to four (4) feet in height as measured from the roof, and not more than sixty (60) percent opaque; iv) Rooftop features used exclusively for mechanical equipment, elevators, or stairways, provided all of the following conditions are met: a) Such building features are not located on single-, two-, or three-family dwellings; b) The combined coverage of such building features shall not occupy more than thirty (30) percent of the roof area of the floor below; c) Such building features may extend up to sixteen (16) feet above the roof of the floor below; d) Where located within fifteen (15) feet of the wall of the floor below, such building features shall not exceed twenty (20) feet in width as measured parallel to the adjacent wall.C) Other height increases: by variance only*For a number of years, architects suggested that our height and area allowances for elevators was not sufficient.Many variances were triggered by the old standards before the ordinance was changed to allow more flexibility with mechanical equipment.
4. Adopted Shoreland Overlay Height. Below are the additional height regulations that apply to properties in the Shoreland Overlay: The maximum height requirement of all structures is 2.5 stories, 35 feet, unless a more restrictive height requirement applies elsewhere in the zoning code, such as for dwellings with 1-3 units. Height exemptions referenced above (e.g., elevator overruns) do not apply in the SH overlay.Bottom Line: The maximum height of a flat-roofed multifamily building in the Interior 2 Overlay District would be 2.5 stories and 35 feet with a three foot parapet. Parapets are used, in part, to screen mechanical equipment and would not be in addition to any mechanical equipment. Mechanical equipment may occupy up to 30 percent of the roof area up to a maximum height of 16 feet, and cannot be more than 20 feet in width if located within 15 feet from the edge of the building. On properties within the Shoreland Overlay, there are no height exemptions, so 35 feet would be the maximum height for a flat roofed building.
5. Editorial on height increases. Prior to Minneapolis 2040 and the adoption of the Built Form Overlay Districts, height increases were common on new development. The previous comprehensive plan and zoning were ambiguous about minimum and maximum heights, and variances were not required to increase height. While in the Shoreland Overlay District, height increases require a Conditional Use Permit, prior to Minneapolis 2040, they did not require a variance. Since the adoption of Minneapolis 2040 and the Built Form Overlay Districts, far fewer variances in general are being granted, and staff was not able to find an example of any height variances that have been granted for small scale residential development.
6. Proposed Zoning Code Amendments. The City is now in the process of drafting and adopting the second section of the Zoning Code, the Land Use Rezoning Study (LURS). This current rezoning study will create all new underlying zoning districts, which will regulate the uses within each district and apply them in alignment with the Future Land Use designations assigned to each parcel in Minneapolis 2040. Revisiting where built form districts are mapped is not part of the scope of the LURS project.A project website, with proposed zoning map, land use table, and a full draft of the regulations can be found here: https://minneapolis2040.com/implementation/land-use-rezoningstudy/.The project is currently in the public comment period, which was been extended an additional 30 days to March 26, 2023. After which, staff will revise the draft in response to the comments received. A public hearing for the Land Use Rezoning work is tentatively scheduled for the April 24 City Planning Commission meeting. Full consideration by the City Council is tentatively anticipated to take place on May 25, 2023.The Land Use Rezoning draft proposes 17 new zoning districts, which correlate to and implement the 12 Future Land Use categories in Minneapolis 2040.In order to effectively implement Minneapolis 2040 and address the range of uses which may reasonably be allowed on properties guided for a Future Land Use of Urban Neighborhood (UN), it was necessary to create three new zoning districts (UN1, UN2 and UN3), which would apply to various UN guided properties. The draft LURS proposes using the Built Form Overlay District boundaries as a way to determine which UN district should apply to a property:A) UN1 zoning district – proposed to apply to properties with the adopted Interior 1 Built Form Overlay District;B) UN2 zoning district – proposed to apply to properties with the adopted Interior 2 and Interior 3 Built Form Overlay Districts;C) UN3 zoning district – proposed to apply to remaining properties with Urban Neighborhood future land use guidance and the adopted Corridor 3 or above Built Form Overlay Districts and allow more congregate living uses than UN2.
7. A note on the survey question:The methodology of where to apply the UN3 district is open for debate. It is currently proposed to apply widely to all UN guided properties with a built form of Interior 3 or greater; however, this does not need to be the case. If, for example, community input was that there should be fewer places where congregate care uses should be allowed, then it may be appropriate to increase the application of UN2 to more areas that would otherwise be zoned UN3. This was the intent and nature of the first survey question, though admittedly it was initially worded poorly. Where to apply triplexes versus buildings with 4 or more units is a topic regulated by the Built Form guidance in Minneapolis 2040 and implemented by the Built Form Overlay Districts. Changing the boundaries of this would require a comprehensive plan amendment.A) Because there are a relatively few uses allowed in the UN zoning districts, the proposed regulations in the LURS are also relatively few.B) Summary of proposed UN2 requirements: i) In addition to uses allowed in the UN1 district, the UN2 district also allows dwellings with 4 or more units, single room occupancy housing, fraternity/sorority existing on the effective date of the ordinance, and off-site parking lots serving multiple-family residences and congregate living uses, ii) There are several use standards that refer specifically to the UN2 district, including for common lot developments and cluster developments which ensure the minimum lot dimension requirements of the Interior 2 built form overlay are not circumvented for developments with 4 or more units; iii) A full list of the proposed land use allowances for all proposed zoning districts can be found here: https://minneapolis2040.com/media/1927/lurs-uses-allowed-table-draft-handout.pdf
8. Proposed Shoreland Overlay Amendments. As part of the LURS there are some amendments being proposed to the Shoreland Overlay District, to clean up conflicts that exist between the Shoreland Overlay and the new zoning. One such amendment would set a minimum lot size for 4+ units at 10,000 square feet, as opposed to the 7,500 square foot minimum required in BFI2 zoned properties outside of the Shoreland Overlay.

Meg McMahan, Planning Director, City of Minneapolis Community Planning and Economic Development Department.