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AGENDA ITEM:
PREPARED BY:
SUBJECT:
DATE:
INTRODUCTION:
BACKGROUND:
DISCUSSION:
"CELEBRATE PRIOR LAKE'S CENTENNIAL - 1991"
4
DAVID J. UNMACHT, CITY MANAGER
STAFF PRESENTATION ON SHORELAND
MANAGEMENT RESEARCH
MARCH 4, 1991
The purpose of this item is to present the
research prepared by staff at Council's direction
on Shoreland Management. A recent variance
application from Paragon Homes resulted in
Council's direction to staff to conduct research
on the interpretation of our ordinance as it
applies to combining substandard lots in the
Shoreland District. Council should be aware that
an additional application is before
staff requiring an interpretation decision again.
Staff would like direction from Council prior to
this matter being acted on by the Planning
Commission and City Council.
On January 4, 1991, Mayor Andren received a
letter from the DNR (copy was provided to you)
regarding the City's need to re-evaluate our
Shoreland Management Ordinance prior to January,
1993. On February 19, 1991 City Council approved
a Shoreland Management Grant application which
was forwarded to the DNR on February 22, 1991.
Enclosed is a copy of a letter to the
DNR....please note paragra~h 2 which talks about
staff's intent to make declsions with respect to
our review process beginning in June.
Subsequently, the point of this issue is to
provide direction to staff only on interpretation
of the common ownership section of the Shoreland
Management Ordinance.
Staff's research is presented in a memo from
Director of Planning, Horst Graser. The memo is
broken down into the following categories:
history, definition of issue, application, impact
and recommendation. Of most importance is the
information contained in the a~plication section
which discusses the number of lmpacted lots and a
comparison of other communities. The issue in
essence is: does the Council want to continue
with the existing interpretation until such time
4629 Dakota 51. 5.E., Prior Lake, Minnesota 55372 / Ph. (612) 447-4230 / Fax (612) 447-4245
An Equal Opportunity/Affirmative Action Employer
,
ALTERNATIVES:
that the Shoreland Management Ordinance is
amended? Staff is reviewing the new rules and has
talked with the DNR. Indications are that they
will be requesting us to change our
interpretation of this section of our ordinance.
Pat Lynch, Area Hydrologist, will be in
attendance representing the DNR staff.
Our current interpretation and resulting variance
procedure is a contentious process with the
public. with few exceptions, our experience has
been for objections to occur either at the
applicant, or at the neighborhood level. These
issues have and will probably continue to come
before the City Council for a ruling and a
verification of your interpretation of this
provision.
The alternatives are as follows:
1. Take no action and continue with your existing
interpretation of the common ownership
provision of the ordinance.
2. Direct staff to interpret the ordinance
consistent with the revised intent of the
DNR's rules and regulations.
3. Do not take an~ action on this issue and
continue to reVlew the interpretation on a
case by case basis.
4. Direct staff to conduct further research on
the matter prior to taking any action.
RECOMMENDATION: This is a difficult decision for staff to develop
a conclusion on. Staff can appreciate both sides
of the issue in this respect: 1) The
recognition of need for this action on behalf of
the DNR, yet it is difficult to quantify in Prior
Lake's case the positive aspects of the DNR's
action on a short and long term basis. 2) We
can understand both the potential positive and
negative reactions from our community residents
on the change in interpretation. So what do we
do? Given the assumption that sometime between
now and January 1993 we face DNR pressure to
change our interpretation, our leaning is toward
changing the interpretation now as opposed to
later. Council mar want to seek in~ut from Lynch
on the DNR's positlon and if there lS any areas
of discussion and/or compromise on this
interpretation issue. Staff can manage this
interpretation in either direction that the
Council provides.
Action will depend on Council discussion and
direction.
ACTION:
MEMORANDUM
DATE:
DAVE UNMACHT, CITY MANAGER
HORST GRASER, DIRECTOR OF PLANNING
ISSUES RELATIVE TO COMBINING SUBSTANDARDS
LOTS IN THE SHORELAND DISTRICT
FEBRUARY 15, 1991
TO:
FROM:
RE:
HISTORY:
In May of 1987, Prior Lake pa~sed the Shoreland Management
Ordinance substantiall~ increaslng the standards for shoreland
development. The adoptlon of the Shoreland Management Ordinance
(SMO) was mandated by the DNR who also developed the standards
for the model ordinance. All communities and counties in
Minnesota were or will be required to adopt DNR shoreland
regulations.
We can view this mandating shoreland program as an indication of
land management involvement for the DNR. Prior to 1980 the DNR
was primarily involved in providing access to natural resources
and managing wildlife systems. Today this position has been
elevated to an active management program of our resources.
Apparently the DNR is of the opinion that a proactive position is
necessary to manage the state's resources since cities and
counties have failed to do so. Indications are that the DNR's
new role in land use management to protect water quality will
continue to grow and expand to other resources as well.
The lakeshore management regulations are essentially zoning
restrictions which have their basis and foundation in
hydrological modeling. These standards vary based on the
category of lake. Local communities are then asked to adopt
them. It must be kept in mind that prior to this point in time
local governments have had little or no input. In most cases the
state shoreland zoning standards exceed local land use
regulations. Any time higher land use standards are adopted,
many previously permitted uses are relegated to legal non
conforming uses. In short, the actions of society lag
significantly behind the events that caused the perceived
problem.
DEFINITION OF ISSUE:
The issue this memorandum explores is whether two or more
adjacent and commonly owned lots of record should be combined and
developed as one lot or allowed to be developed as substandard
individual lots. This issue was the subject of considerable
debate during the SMO adoption process. Metro area hydrologist,
Mike Mueller, interpreted Rule 6120.3300 20 for the DNR stating
that substandard lots of record need
ownership at the time of building permit
1988, letter to Mayor Andren). Such an
commit city residents to combining and
lakeshore management district lot sizes.
in force today.
The problems these issues are attempting to address are the
sources of pollution and land use practices that contribute to
the deterioration of water quality and quality of life when it
comes to water related experiences. Attempting to define and
quantify sources of pollution in todays environment is difficult.
What will be even more difficult is changing our land use
practices and way of living to maintain or improve water quality
and environment.
onl~ be in separate
appllcation (June 10,
interpretation did not
uP9rading substandard
ThlS interpretation is
The substandard contiguous lot issue was the focus of a recent
variance appeal to the City Council (VA90-20 Greg Schweich of
Paragon Homes). Several of the neighbors objected to the
lakeshore variance based on the idea that the two contiguous
lakeshore lots should be combined as each separately would
present an inadequate and too small a building envelope.
The direction for this memorandum was one of the outcomes of this
variance hearing. The Council wanted to explore a stricter
interpretation for developing substandard lots of record. A
stricter interpretation would require a group of two or more
contiguous substandard lots under the same ownership to be
combined with one or more conti9uous lots so they equal one or
more parcels of land each meetlng the requirements of the zoning
ordinance as much as possible.
APPLICATION:
In December of 1990 the Planning Department
determine the number and location of two or
of record under common ownership in the
district. The results were unexpected.
conducted research to
more substandard lots
shoreland management
Total number of lakeshore properties
with at least two substandard lots
of record under one ownership. 117
Total number of non lakeshore properties
with at least two substandard lots of
record under one ownership. 83
Total number of lakeshore properties
with a combination of lakeshore and
non lakeshore lots of record under one
ownership 7
Total: 207
Of the 207 properties that would be affected by the application
of a stricter standard only 22 have not been developed. The
undeveloped properties are not concentrated in anyone
neighborhood but are spread throu9hout the shoreland district.
There may be other considerations WhlCh would prevent separation
of the 22 vacant lot combinations, such as topography or unusual
lot dimensions. However, those types of factors were not
researched. Of the 22 vacant lots, 9 were lakeshore lot
combinations.
One hundred eighty five properties of the 207 are developed with
structures ranging from new homes to old cabins. If the
structure is removed or demolished from a combination property
than each lot could be developed separately. Time did not permit
us to define this group of combination properties to determine
the potential number of splits. These combination properties
have the following characteristics:
1. "Nestegg Concept" where one or more lots in a homestead
situation is held for sale or investment.
2. Properties are combined to form a lot that is developed
with a newer home that because of the sizable investment
cannot be removed.
3. Properties that have older homes which may straddle
property lines but are candidates for future demolition
as circumstances present themselves.
4 .
Properties that are developed with cabins or
homes of various ages and structural integrity.
structures ma~ be easily demolished or moved
adjacent lot ln anticipation of a sale.
summer
These
to the
Demolition or removal of older structures is going to occur more
frequently as vacant lakeshore decreases and the value of
lakeshore increases. In the last 5 years Prior Lake has issued
26 demolition permits to lakeshore properties.
Scenarios 1-3 above were difficult to quantify without extensive
research and field checks. However, scenario 4 above, was
quantified using building permits and year built information
which was available in the Prior Lake computer data base and the
least costly method of research. Of the 185 combination
properties, 39 structures were built prior to 1950. Seventeen of
the 39 structures were built prior to 1940. This study assumes
(not verified by field checks) that these are cabins perhaps
subject to demolition. Of the l7 structures before 1940, II are
located on lakeshore properties. Most of these structures are
located in Inguadona Beach, Red Oaks, and Point Beautiful
subdivisions.
Of relevance and importance is that 14 combination properties out
of the l85 have structures on them but no building permit record
exists either in Prior Lake City Hall or Scott County. We can
assume that these properties are extremely old and may be subject
to demolition.
other communities in the metropolitan area have also been
struggling with substandard lots. This study solicited
information from some of these communities to serve as a base of
comparison for possible action. Every community that was
solicited has dealt with or is about to address substandard lots.
A most interesting result was that, with the exception of
Plymonth, the smallest lakeshore
communities surveyed was 20,000 square
60,000 square feet. Prior Lake's
square feet.
lot size in any of the
feet and the largest was
current lot size is 15,000
In the City of Minnetonka, the minimum lot size is 22,000 square
feet with no vacant lakeshore lots. They consider substandard
lots to be between 22,000 and 15,000 square feet and be buildable
with variances. Anything smaller does not receive variances.
The City of Chanhassen has a 20,000 square foot minimum lot size.
Their substandard lots must be at least 75% of the current
standard otherwise they are not buildable.
In the City of Orono, the minimum lakeshore lot size is 1/2 acre.
It is their policy to combine substandard lots by not granting
any variances.
The lot size in the City of Deephaven range from 20,000 to 60,000
square feet. They have not adopted shoreland regulations and
encourage substandard lots to be combined. Variances are not
issued to substandard lots.
The cities of White Bear Lake and Wayzata have adopted shoreland
regulations and interpret them similar to Prior Lake.
The City of Shorewood has a minimum lakeshore lot size of 40,000
square feet. In order for a lot to be buildable it must be at
least 70% of the size and width of the current requirements or it
is not buildable.
The City of Plymonth has adopted shoreland regulations with a
minimum lakeshore lot size of 15,000 square feet. This community
has adopted provisions for combining substandard lakeshore lots
under one ownership.
Paramount to any action relative to substandard lots is the legal
issue of "taking". Sherri Ulland, Attorney with Lommen, Nelson,
Cole & Stageberg P.A., researched the "taking" issue. She
concluded that there would be no "taking" since the owners of all
substandard lots will not be deprived of all reasonable use of
their property if they are forced to combine their lots.
Further, she states, that owners will not be able to show a
substantial diminution in value because the property can still be
sold or developed as long as it is combined with one or more
contiguous lots. (memorandum from Sherri Ulland, January 28,
1991) .
Of equal importance on the issue of "taking" is a 1988 court case
in Hennepin County. The City of Shorewood in 1985 enacted a
zoning code change that established an absolute minimum buildable
lot size which 1S 70% of the current 40,000 square foot standard
or 28,000 square foot. The plaintiffs have owned a vacant 50
foot lakeshore lot (10,950 square foot in area) since 1956, at
which time it was buildable. In 1986 the plaintiffs were denied
a building permit by the Planning Commission and City Council.
The court ruled as follows:
The Court is compelled to the conclusion that there
has been no taking because plaintiffs still enjoy a
reasonable use of their property, the use to
which the property has been put for the last 30
years - swimming, boat storage and dockage, and
access to the lake. Noth1ng in the zoning
ordinance prevents plaintiffs from using their
property for the above purposes. continuation of a
present use is a reasonable use even if it may not
be the most profitable use.
IMPACT:
It is impossible for this study to attempt to measure the
these alternatives will have on the problem. Perhaps
absence of quantifiable data, decision makers must look at
alternatives in an abstract way.
The DNR has defined and delineated in a comprehensive way sources
of pollution. Inappropriate land use practices are but a part
of the water quality problem. Based on their knowledge, testing,
and expertise, they have concluded that a stricter land use
practice such as larger lakeshore lots is a positive water
quality management tool.
impact
in the
these
Earlier in this text it was stated that 207 combination
properties exist in the Prior Lake Shoreland District. One
hundred seventeen of these are lakeshore properties.
Theoretically the current zoning code would allow an additional
207 homes to be build, 117 of those could be built on substandard
lakeshore lots. A vast majority of the substandard lakeshore
lots are 50 foot wide and between 7000 to 10,000 square feet in
area. Most of the other cities surveyed do not issue building
permits to lots of that size.
Several months ago, Prior Lake received official notice that
within two years the DNR's latest shoreland regulations must be
adopted. One of the components of the new regulations is the
requirement that substandard lakeshore properties must be
combined. This DNR undertaking has been predictable since local
jurisdictions and their disinterested experts have found little
relevance in strengthening the bond with other governments to
collaborate in overcoming uncertainties.
RECOMMENDATION:
staff is inclined to seek whatever
immediately. Water is a common and
community. Its value is being threatened
of common and mutual goals. This threat
should be dealt with as quickly as
shackle the potential of this community.
remedy is available
shared resource to our
along with the security
is not an idle one and
possible so it does not
d
~" L /~ I
~ / /;tP
"CELEBRATE PRIOR LAKE'S CENTENNIAL - 1991"
February 22, 1991
Mr. Ed Fick
Shore land Hydrologist
DNR Division of Waters
1200 Warner Road
st. Paul, MN 55106
Dear Mr. Fick,
Enclosed is a copy of the state of Minnesota, Department of
Natural Resources Shoreland Grant Application adopted by the
Prior Lake City council on Tuesday, February 19, 1991. The City
of Prior Lake is interested in participating in your Shoreland
Grant Application Program.
We received our official notification to revise our Shoreland
Management Rules on January 4, 1991. Currently we are evaluating
a section of our ordinance, but we have not undertaken an
aggressive action to evaluate the entire ordinance in order to
make it compliant with the new Shore land Grant Rules and
Regulations. We intend to make decisions with respect to our
renewal process beginning in June, 1991.
If ~ou have any questions with respect to our application or our
reV1ew of the Shoreland Management Ordinance, please feel free to
contact me. Please keep me informed as to the status of our
grant application. Thank you for your consideration.
/' nc~rT fur
Ovid J. Unmacht
c'ty Manager
ity of Prior Lake
DJU : db
cc: Horst Graser
Deb Garross
4629 Dakota 51. 5.E., Prior Lake, Minnesota 55372 / Ph. (612) 447-4230 / Fax (612) 447-4245
An Equal Opportunity Affirmative Action Employer
3TATE OF MINNESOTA
DEPARTMENT OF NATURAL RESOURCES
SHORELAND GRANT APPLICATION
WHEREAS, the State, as provided by Minnesota Statutes 103F .201-221 and
Minnesota Rules parts 6120.2500 through 6120.3900 pertaining to Statewide
Standards for "Management of Shoreland Areas"; and
WHEREAS, the State is authorized by the Laws of 1989, Chapter 335, Article
1, Section 21, Subd 3 to provide grant assistance for Cities to adopt a shoreland
management ordinance consistent with statewide standards.
NOW THEREFORE, subject to available funding, it is hereby requested by
the City of ~,~~ that an agreement be entered into by
the State of Minnesota, acting by and through the Commissioner of Natural
Resources and the City of
/?vn ~
, to provide grant money
assistance up to $5,000.00 matching fund dollars, for the purposes of adopting
a shoreland management ordinance consistent with statewide standards.
--/
BY: ---,./<..../~-<
L----'" /'
/
Mayor
DATE: ~ Ujlff/
/----
//
(' //_-L_7~ L..--~-<""
"CELEBRATE PRIOR LAKE'S CENTENNIAL - 1991"
TO:
Mayor and City Council
David J. Unmacht, City Manager
March 1, 1991
RE:
AGENDA ITEM 4 - REGULAR COUNCIL MEETING
March 4, 1991
The purpose of this short memorandum
the Staff Report for Agenda Item 4.
Attorney, Glenn Kessel, I would
Alternative Sections - #2 and #3:
is to clarify a section of
After a discussion with City
like to clarify, in the
Alternative #2
If this alternative is selected, Glenn is recommending that
the City Council amend the ordinance to reflect their revised
intent. In other words, if the City Council wants to proceed
with changing the interpretation, the motion should NOT be to
direct staff to interpret the ordinance consistent with the
revised intent of the DNR Rules and Regulations, rather, the
motion should be to direct staff to develop a revised
ordinance to be consistent with the revised intent of the DNR
Rules and Regulations. We would then proceed with the
ordinance amendment process. I would add that we would not
have to notify all affected property owners with respect to
this ordinance change, but simply follow our standard
ordinance amendment procedure.
Alternative #3
Eliminate #3 entirely and substitute that for the following:
Do not take any action on the interpretation issue at this
time, and direct staff to develop an ordinance providing for
a moratorium on the consideration of all variances and
applications related to the common ownership provisions of
the Shoreland Management Ordinance. In effect, this
alternative delays the decision of the Council, however, it
will provide the means by which the City can avoid acting on
these applications until such time that a final decision is
made. This decision could be made at any time between now
and when we are reviewing the Shoreland Management Ordinance.
City Attorne~ Kessel would prepare a moratorlum ordinance for
your processlng.
4629 Dakota 51. S.E., Prior Lake, Minnesota 55372 / Ph. (612) 447-4230 / Fax (612) 447-4245
An Equal Opportunity/Affirmative Action Employer