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HomeMy WebLinkAbout6B Thrive MSP 2040 Draft Comp Dev Guide ReportFRto u °7. 4646 Dakota Street SE Prior Lake, MN 55372 PLANNING COMMISSION AGENDA REPORT MEETING DATE: APRIL 7, 2014 AGENDA #: 6B PREPARED BY: DAN ROGNESS, COMMUNITY & ECONOMIC DEVELOPMENT DIRECTOR PUBLIC HEARING: NO AGENDA ITEM: THRIVE MSP 2040 — DRAFT COMPREHENSIVE DEVELOPMENT GUIDE DISCUSSION: Introduction The purpose of this item is to review the Metropolitan Council's Thrive MSP 2040 Draft Comprehensive Development Guide. Cities are being asked to review this document and provide comments to the Metropolitan Council by April 28. History On March 3, the Planning Commission reviewed preliminary 2040 forecasts for population, households and employment. This is a necessary first step in the 2040 comprehensive planning process (Thrive MSP 2040). Now, the Metropol- itan Council has completed a Draft Comprehensive Development Guide for public comment. Current Circumstances The guide provides regional guidance while recognizing the need for specific place -based policies. Community designations have been established, including five within the urban service area and four within the rural service area as follows: Urban: (1) Urban Center, (2) Urban, (3) Suburban, (4) Suburban Edge, and (5) Emerging Suburban Edge. Rural: (1) Rural Center, (2) Diversified Rural, (3) Rural Residential, and (4) Agri- cultural. Conclusion City staff is providing the following document comments for review by the Com- mission: 1. The document expands Metropolitan Council's authority into areas be- yond its core planning and service functions. Examples of this include water, solar energy, climate change and poverty. It should continue to focus and improve upon existing core competencies before considering new areas. 2. The document provides no metrics to help further explain Metropolitan Council direction, including when targets are met. 3. The document has no fiscal note for either the Metropolitan Council or for cities that are subject to expansive and ongoing requirements. 4. The Emerging Suburban Edge is an accurate description of Prior Lake. However, the differences between the Suburban Edge and the Emerg- ing Suburban Edge are minor, resulting in a question as to why two sep- arate "edge" community designations are necessary. 5. If one assumes that regional investments become less as you move from the Urban Core to the Suburban Edge, then there should not be two "edge" communities. 6. The three largest cities in Scott County (Shakopee, Savage, Prior Lake), work as equal partners through SCALE on many initiatives and projects. Due to that history of cooperation, Prior Lake views itself as more similar than different to Shakopee and Savage. However, the Metropolitan Council's guide separates Prior Lake from them in terms of the commu- nity classification. 7. If Prior Lake remains in the Emerging Suburban Edge category, then the average housing density should change from 3-5 units to 3 units per net acre. 8. With significant land holdings of SMSC in Prior Lake (and Shakopee), the guide should give some recognition of land use impacts of large land owners in the Twin Cities. Other examples may include the University of Minnesota/MnSCU, MSP international airport and larger farms. 9. Prior Lake agrees with the most recent Metropolitan Council's 2040 fore- casts for its population at 39,300 (550/year), households at 15,700 (245/year), and employment at 12,500 (160/year). ISSUES: The Planning Commission should discuss the Metropolitan Council's draft development guide and provide input to the City Council, which will also review the document on April 14th. The Council's comments may then be forwarded to the Metropolitan Council by the deadline of April 28. ALTERNATIVES: 1. Provide comments as recommended by City Staff, or as further amended by the Commission. 2. Table action and ask City Staff to provide additional information as re- quested by the Commission RECOMMENDED Staff recommends a motion and second in support of Alternative #1 MOTIONS: ATTACHMENTS: 1. Excerpts and highlighted sections of the Thrive MSP 2040 Comprehensive Development Guide. 2. Table comparing Suburban community designations. 3. Draft comments from Metro Cities (organization representing metro cities). 4. See full document at http://www.metrocouncil.org/Planning/Publications-And- Resources/Thrive-for-Public-Review-and-Comment.aspx dL- F-Ar 20 4a Thrive ►�1�� �t ,i j ONE VISION, ONE METROPOLITAN REGION DRAFT r/ , f/ G PSL §f�w 1 Last revised: February 20, 2014 The Metropolitan Council has released the comprehensive development guide for the Twin Cities metropolitan area, Thrive MSP 2040, for public comment. The public is encouraged to view the plan and provide public comment, through Monday, April 28, as follows (comments must be received by b p.m.): • Written comments: Metropolitan Council 390 N. Robert St., St. Paul, 55101 • Fax comments to: 651-602-1464 • Send TTY comments to: 651-291-0904 • Email: Public.info(@metc.state.mn.us • Record comments on Council's Public Comment Line at 651-602-1500 • Submit comments through the Council's online Your Ideas site, at httP://Uoi.irideas. metrocoui7ci1. orc�/. The Metropolitan Council will hold two public hearings on the Thrive MSP 2040 plan: Thursday, April 10, 6 p.m. F.T Heywood Office Building, Chambers 560 Sixth Avenue North, Minneapolis Served by regional transit routes 5, 19, 22, and METRO Blue Line Wednesday, April 16, 6 p.m. Metropolitan Council Chambers 390 Robert Street North, St. Paul Served by many regional transit routes All interested persons are encouraged to attend the public hearings and offer comments. Those attending may register in advance to speak by calling the Council at 651-602-1140. Upon request, the Metropolitan Council will provide reasonable accommodations to persons with disabilities. Advance notice, indicating the specific accommodation needed, is appreciated. Staff will review public comment and evaluate changes to the document to address the comments submitted by the public. A recommendation for final adoption of the Thrive MSP 2040 plan will be considered by the Metropolitan Council in May 2014. Special Features Applying policies to specific places: Moving beyond one size fits all The previous sections outlined the outcomes and principles that describe the Thrive MSP 2040 vision for the Twin Cities area. Within our region, communities are growing, developing and redeveloping in different ways. Recognizing that one size does not fit all, the Council has identified key places that situate the Council's priorities in specific geographies and that require specific place - based policies. While some of the Council's policies apply throughout each jurisdiction's borders, the policies outlined in this section recognize both granular variation within communities and commonalities that transcend community borders. When local communities begin their own comprehensive planning process, they will address the intersection of and integration across these special features; for simplicity of description, this section discusses each special feature independently, Special features provide enhanced granularity for policies that vary within jurisdictional boundaries; others focus policy implementation on features that transcend local borders. Special features allow the Council to apply policy consistently to land with specific levels of infrastructure or service, certain demographic traits, similar urban form, or particular geological or topological characteristics whether within or across jurisdictional borders. Some special features are static, describing fixed topographical characteristics; others are dynamic, reflecting changing infrastructure or socioeconomic characteristics. The Council's policies will be stable over the lifetime of this plan while the geographies that they affect may change. This section discusses four special features to emphasize the strong roles they play shaping how the Council wants the region to grow and develop, In addition, several long-standing Council priorities that strongly shape regional planning are described. When updating their local comprehensive plans, the region's communities will address both "special features" and "community -wide" policies into its own unique situation. CRAFT FOR PUBLIC COMMENT Last revised: February 26, 2014 43 Racially Concentrated Areas of Poverty and Areas of Concentrated Poverty The Council's Choice, Irl0cmerrd Place and Opportunity.- An Equity Assessment of the Twin Cities Region (2014) I_ identified Racially Concentrated Areas of — Poverty (RCAPs), contiguous areas of one or more census tracts in which at least 50 percent i of the residents are people of color and at least 40 percent of the residents live in households with incomes below 185 percent of the federal poverty line. ($42,589 in annual income for a four - person household in 2011) By 2010, nearly one in ten of our region's residents lived in racially concentrated areas of poverty, While statistical sampling means that the borders of RCAPs and areas of concentrated poverty are imprecise, the cores of these areas demonstrate remarkable and unwelcome persistence over time. Because both racially concentrated areas of poverty and areas of concentrated poverty limit the economic mobility of their residents and discourage private investment, our region simply cannot afford to allow these areas to persist or grow. Using public resources to catalyze investment these areas, the Council will seek to help the region grow and prosper more equitably. The Council will work with partners and use its investments and actions to improve access to opportunity for residents and attract private investment so that all people live in communities that provide them access to success, prosperity, and quality of life. Visit the Council's website for the most current delineation of racially concentrated areas of poverty and areas of concentrated poverty. For specific approaches, policies and additional analysis related to racially concentrated areas of poverty and areas of concentrated poverty, see: • the Equity section of the Thrive Outcomes (starting on p. 19); • Choice, Place and Opportunity: An Equity Assessment of the Twin Cities Region. DRAFT FOR PUBLIC COMMENT Last revised: February 26, 2014 44 Station Areas on Existing and Planned Transitways Transitways are major investments that provide faster service than regular -route buses, better customer experience, and more certainty to the city and investors that can attract development.. Transitways can be commuter rail, light-rail transit, bus rapid transit, arterial bus rapid transit, or potentially streetcars. The areas around transitway stations can accommodate regional growth; offer expanded living, working and shopping choices; increase the efficiency of existing infrastructure, and contribute to climate change mitigation and resiliency. However, the investment required to construct transitways is both significant and long term. As the region expands its network of transitways in the coming years, good stewardship requires that the region maximize their value, cost- effectiveness and performance. To this end, the Council will prioritize locations that have city and corridor commitment to transit -supportive development patterns near stations, including higher levels of density and development. The Council will provide technical assistance to support transit -oriented development in station areas. Transitway corridors are able to provide transportation access to more residents and employers, especially in higher density areas, and therefore accommodate more of the region's expected growth and development. In addition to their role attracting growth and development, the prospect of future transitway corridors also provides an incentive for communities to cooperate and collaborate across jurisdictional borders. The map above is intentionally illustrative. See the most recent Transportation Policy Plan for a formally adopted map of planned transitways and station areas. For specific approaches, policies and additional analysis related to station areas along transitways, see: • the Stewardship section of the Thrive Outcomes (starting on p. 9) • the Orderly and Efficient Land Use policy (p. 64) • the Access, Mobility and Transportation Choice Land Use policy (p 74) • the Transit Oriented Design Strategic Action Plan • the 2040 Transportation ,policy !Tarr and its supporting technical appendices. DRAFT FOR PUBLIC COMMENT Last revised: February 26, 2014 45 Water Supply Considerations The Mississippi River supplied water to early development in the region, but groundwater wells have been used to accommodate the region's outward growth. This increasing reliance on groundwater overtime has become a significant issue. In parts of the region, groundwater levels are declining. In some cases, it is affecting, or has the potential to affect, lake levels. A pressing concern is the impact that future development could have on the reliability of groundwater as a water source. Figure 1. Sustainable water Supply j w N rew ement�l tee: I IFf I b t6M t -J RoY ky to SMace Wage* * la4esalawvs In 2005, the Minnesota State Legislature authorized the Metropolitan Council to ` take on planning and management of ,,.;h ti regional water supply issues. The Council's goal, articulated in the Master 1 Water Supply 1 Plan is a sustainable water supply for current and future ' — generations. To achieve this goal, the Plan identified two important issues to address: the unbalanced use of groundwater versus surface water resources, and the unplanned modification of important groundwater recharge areas. Figure 1 identifies the communities that sustainable water use can be re-established through a better balance of groundwater and surface water supply, and through better management of vulnerable recharge areas. Cities are responsible for planning their local water supply and obtaining permits from state agencies. These agencies, which protect the state's water resources and ensure safe drinking water, include the Minnesota Department of Natural Resources (DNR) and the Minnesota Department of Health, Because of the Metropolitan Council's planning work completed with the Master Water Supply Plan, the region now has a better understanding of the impact of development and water use on underground aquifers, as well as potential solutions to long-term sustainability. As communities plan for the future, they should consider both the implications of their water supply for future growth and how their land use patterns affect water supply. The map above is intentionally illustrative. See the Council's website and the Master Water Supply Plan for up-to-date maps of groundwater recharge potential. For specific approaches, policies and additional analysis related to groundwater, visit: • the Sustainability section of the Thrive Outcomes (p. 29) • the Orderly and Efficient Land Use policy (p. 64) • the Water Sustainability Land Use policy (p. 69) • the 2040 Water Resources Policy Plan • the metropolitan area Master Water Supply Pian. DRAFT FOR PUBLIC COMMENT Last revised: February 26, 2014 46 Job and Activity Centers Job and Activity Centers are areas of focused economic activity areas that have at least 7,000 jobs at a net density of at least 10 jobs per acre. In 2010, half of the region's jobs were located L�°'°""M"°R`W" in one of 42 Job Centers; one in six of the o •„k, region's jobs was in the four largest jobJoE sp+Ra., 2011 xuit centers: downtown Minneapolis, downtown �`�•” �1b19 Saint Paul, the University of Minnesota and Q6bF9 the airportlMall of America. Activity Centers are concentrated nodes of other activity, such as major educational institutions, shopping and airports. Job and Activity Centers benefit from significant existing regional infrastructure such as wastewater, highways, and transit, as well as local infrastructure investments in access and connectivity like sidewalks, parking, water, parks, and trails, Building on these investments to take advantage of new opportunities to adapt, reuse, or redevelop properties will maximize the benefit of our regional investments and support the continued orderly and economical development of the region. Job Centers are contiguous Job and Activity Centers are significant travel destinations and support higher levels of transit service and highway infrastructure. Employers that value transit access for their workforce should locate in Job Centers. Due to the advantages and efficiencies that these locations provide, the Council will partner with key stakeholders to promote job placement and growth in Job Centers. As new job concentrations emerge—whether through new development, redevelopment or job growth at specific sites—the Council will identify Job Centers that meet the thresholds of job number and density. The map above reflects 2011 data. See the Council's website for annually - updated maps of Job and Activity Centers. For specific approaches, policies and additional analysis related to Job and Activity Centers, visit: • the Prosperity section of the Thrive Outcomes (p. 13) • the Economic Competitiveness Land Use policy (p.77) • the 2040 Transportation Policy Plan and its technical appendices. DRAFT FOR PUBLIC COMMENT Last revised: February 26, 2014 47 Wastewater Service Areas The Council has a long history of aligning land development with the staging of new connections to regional wastewater service. This has helped the Council to provide efficient and affordable service; to create predictability for landowners, cities and developers; to ensure that future revenues cover the expense of the infrastructure; and to protect ground- _ and surface -water quality. Many ( Council policies relate to a Jim community's level of wastewater service: Wastewater Service Area is I_ land currently served by the regional wastewater treatment system. Planned Wastewater Service y' Area includes land that is not currently served but is staged to receive regional wastewater treatment service by 2040. • Long-term Wastewater Service Area represents land that is planned to receive wastewater treatment service sometime after 2040. To further stewardship of the region's water and financial resources, the Council will continue to apply established wastewater policies. Additionally, wastewater operations and investments will be aligned with other activities as part of the Council's new water sustainability approach. As a long-standing responsibility of the Council, wastewater service polices are woven into the community designations outlined in the next sections. In order to ensure efficient use of regional infrastructure, the Council defines minimum residential density levels in areas planned for regional wastewater service by 2040. In areas planned for post -2040 regional wastewater service, the Council defines maximum residential densities. The map above is intentionally illustrative. See the Council's website and adopted amendments to the Water Resources Policy Plan for up-to-date maps of the long-term wastewater area and the Metropolitan Urban Services Area. For specific approaches, policies and additional analysis related to wastewater service policies, visit: • the Stewardship and Sustainability sections of the Thrive Outcomes (p. 9 and 29) • the Water Sustainability Land Use policy (p. 69) • the Orderly and Efficient Land Use policy (p. 64) • the 2040 Wafer Resources Policy Plan. DRAFT FOR PUBLIC COMMENT Last revised: February 26, 2014 48 Regionally Significant Ecological Resources An abundance of natural resources is one of the many reasons that our region is so vibrant and desirable. The region is home to a wide variety of natural habitats, ranging from wooded riverine areas along the Minnesota and St. Croix Rivers to large wetland complexes like that in Carlos Avery Wildlife Management Area to upland prairies and forests throughout the region. Ecological resources are important to the Council because of the many benefits that come from a healthy natural environment, including economic activity, health and psychological benefits, quality of life and valuable eco - services. The health of these natural systems depends on active protection and management by a wide variety of agencies, communities and individuals. The Council plays several roles in this network: collaborating with state and local partners to protect and improve water availability and quality, preserving and protecting high quality environments in regional parks in partnership with local parks agencies, and coordination of land use planning by local units of government. Integrating natural resources into our development patterns helps to create livable neighborhoods and desirable places to visit. Incorporating natural areas and trees into neighborhoods adds to a community's sense of place, as well as providing opportunities to interact with the natural environment on a daily basis. Some natural areas can also increase opportunities for outdoor recreation and exercise, especially when integrated into the neighborhood. As communities embark on their comprehensive plan updates, the Council will provide technical assistance and information on natural resources, best practices for protection and integration into development. The map above is intentionally illustrative and contain information about the variety of natural features — including lakes, rivers, creeks, wetlands, and upland areas. The Council will continue to partner with agencies and stakeholders to compile and distribute such information, and will assist local communities with finding and incorporating this information in their local planning processes. For specific approaches, policies and additional analysis related to regionally significant ecological areas, visit: a the Stewardship and Sustainability sections of the Thrive Outcomes (p. 9 and 29) • the Natural Resources Protection Land Use policy (p. 66). DRAFT FOR PUBLIC COMMENT Last revised: February 26, 2014 49 Communitv Designations The previous sections of Thrive MSP 2040 set forth Outcomes and Principles to guide regional policies, investment and activities. This section translates those overall ideas into specific land use policies and strategies to help local communities incorporate regional needs into local comprehensive plans, The seven -county region contains a wide range of communities, from Agricultural areas to the Urban Center. Development patterns, neighborhoods, and land uses vary across communities. To advance the Thrive Outcomes, the Council is articulating specific land use and development strategies and policies tailored for communities with shared development opportunities and challenges. This approach allows each local jurisdiction the flexibility to determine how to best work toward achieving both the regional outcomes and their local goals. The Council assigns a community designation to each city and township based on the overall state of development and regional issues faced by that community. Although the characteristics of the community designation may not apply to every neighborhood of a community, the designation represents the dominant character of the community. The Council uses these community designations to: • guide regional growth and development to areas that have urban infrastructure in place and the capacity to accommodate development and redevelopment; • establish land use expectations, including overall densities and development patterns, for different planning areas; • outline the respective roles of the Council and the individual communities and strategies for planning for projected levels of growth. Urban and Rural Service Areas The Council designates the Metropolitan Urban Service Area (MUSA) to distinguish between the Urban Service Area and the Rural Service Area. Communities within the Urban Service Area receive a higher level of regional services such as metropolitan wastewater services, regional highways, and the regular route transit. In return, the Council expects these jurisdictions to plan for and build the higher levels of development that economically support those regional services. Conversely, in the Rural Service Area, the Council discourages higher development densities to ensure the orderly development of the region, promote the efficient use of regional investments, and to protect agricultural land, water resources, and the rural landscape. While the Urban Service Area constitutes about half of the land in the region, over 90% of the population lives in this area. The Urban Service Area includes a diverse set of communities ranging from the urban cores of downtown Minneapolis and St. Paul to suburban edge communities planning for staged growth and expansion. Developing at different times in the region's history, these communities include a variety of residential neighborhoods, housing types, and densities, as well as a varying mix of commercial and industrial areas. The Council supports the Urban Service Area through investments in transit infrastructure, transit services, highways, regional sewer systems, the regional parks system, and programs that support redevelopment. In turn, the Council works with local communities to support growth that best capitalizes on regional infrastructure and systems. To respond to this variation in development DRAFT FOR PUBLIC COMMENT Last revised: February 26, 2014 50 patterns, the Metropolitan Urban Service Area is divided into five community designations: Urban Center, Urban, Suburban, Suburban Edge, and Emerging Suburban Edge. About half of the land in the Twin Cities region is in the Rural Service Area. This area includes a range of uses including cultivated farmland, vineyards, hobby farms, gravel mines, woodlands, small towns, scattered and clustered housing, open spaces and significant expanses of the region's natural resources. Aside from the investments in the regional parks system, investments in regional service are limited in the Rural Area. To protect the vital agricultural lands and natural amenities and accommodate desires for rural and small-town residential choices, the Rural Area is divided into four community designations: Rural Center, Rural Residential, Diversified Rural, and Agricultural. DRAFT FOR PUBLIC COMMENT Last revised: February 26, 2014 51 i st luxe faw� I l.L�r, d twv c", -. N, &,-, Lt- i Fa f:S L f S»!i �% ccan eqv, 1j LN Litt" WMit, it C, u L'tvr.R 1 taxrfi;<<R Iti`^,! TIN r- i' }t`,.lta ShW late rptM1y, ,aA' {.riv} ilyb G.nf 11,11-111,4"esti S L14i!! Elsa rp ISCYrrM V y ti . � h..a,.#n � �ro�` nTiirxa I lj fssd 1 Lp l.i claytict1� Kk4ue<.rLr.:+t� .l t w — trr as eai Hi,{w'f Mepy rai, ' r4rlafrwa7xv� St rpAlk ,tinn MP.. t -ago vow Loy Li a �. han SAr:k>5'rtl lr, rryfiy { .! Hh�.r4r*1 Lw ,• lyd. U4 a, . t rl,`nl5ery Pbl LyirP.f-aa I lr<<Lr.t �e :<n Ta" F�, Mrdkti.'fJ I I. 1r 1� !I I r .rj swve..oc/iktlR I . �~r•;a.r I r:-., ' —,;'. ` u:rla I, n, � l � y�l r CRhehriFM L4 h.i: i ��L � 1 'e�,'• T a, � �„�v � v- r.' }-...,T.' Community Designation Rural center 70 I1 Urban Center Diversified Rural M -Its Urban Rural Residential January 3, 2013 Suburban I poricuftural Suburban Edge hon Region Emerg'ng Suburban Edge DRAFT FOR PUBLIC COMMENT Last revised: February 26, 2014 52 Land Use Policies To build the foundation for a prosperous, equitable, livable, and sustainable future, the Council has identified seven policies to guide land use and regional development: Orderly and Efficient Land Use: Align land use, development patterns, and infrastructure to make the best use of public and private investment. Natural Resources Protection: Conserve, restore, and protect the region's natural resources to ensure availability, to support public health, and to maintain a high quality of life. Water Sustainability: Conserve, restore, and protect the quality and quantity of the region's water resources to ensure ongoing availability, to support public health, and to maintain a high quality of life. Housing Affordability and Choice: Promote housing options to give people in all life stages and of all economic means viable choices for safe, stable, and affordable homes. Access, Mobility, and Transportation Choice: Sustain and improve a multi -modal transportation system to support regional growth, maintain regional economic competitiveness, and provide choices and reliability for the system's users. Economic Competitiveness: Foster connected land use options to provide businesses and industries with access to materials, markets, and talent. Building in Resilience: Promote sensitive land use and development patterns to achieve Minnesota's adopted greenhouse gas emissions goals at the regional scale, and to develop local resiliency to the impacts of climate change. To implement these overall policies the Council has identified land use strategies for local communities and the Council to implement. While each strategy is linked to a specific policy in this document, in practice strategies can serve multiple purposes. For example, a strategy of focusing development around centers on transit and transportation corridors supports the policy of aligning land uses to make the best use of public and private investments, among other policies. Guiding development to targeted areas can reduce the development pressures in areas with high quality natural resources. This focus of development along transportation and transit corridors can also improve the efficiency of our transit system by building housing within easy access to the existing system. This method of development can also support specialized housing types to meet the lifestyle needs of a segment of the population seeking more urban living options. We cannot focus on one policy alone to attain the outcomes identified in this plan. Instead, it will take a combination of strategies addressing all of the policies to set the stage for a successful future. While a policy may appear to directly support some of the Council's desired outcomes more than others, all of the land use policies are interrelated and implementation must be integrated to achieve the outcomes. The next section details land use policies for the region, followed by strategies that are common among all communities. In recognition of the opportunities and challenges unique to different communities, additional strategies to implement these policies are tailored to suit the different community types in the region (see Strategies for Community Designations). DRAFT FOR PUBLIC COMMENT Last revised: February 26, 2014 66 Orderly and Efficient Land Use Align land use, development patterns, and infrastructure to make the best use of public and private investment. Orderly and efficient land uses lay the foundation for a prosperous region. The Council sets the framework for land use patterns and guide development in the region, as directed by the Metropolitan Land Planning Acta° This means being fiscally responsible by guiding land uses and development patterns that make the most of the region's investments in infrastructure. Directing growth where infrastructure already exists also reduces the need to add roads and expand the regional wastewater system to support the same growth elsewhere. Making efficient use of land and capitalizing upon existing infrastructure also reduces outward development pressures in rural and natural resource areas. Planning for and supporting growth where infrastructure is already in place allows these rural areas to continue to maintain large tracts of natural resources, agricultural production, and a sparsely developed rural environment. Table 1. Overall Density Expectations for New Growth, Development, and Redevelopment Metropolitan.. , AverageMinimum Net Density Urban Center 20 units/ acre Urban 10 units / acre Suburban 5 units/ acre_ Edge 3-5 units/ acre _Suburban Emerging Suburban Edge Rural Service Area 3-5 units / acre Maximum Density, except Rural Centers Center 3-5 units/acre minimum _Rural 1 -2.5 -acre lots existing, Rural Residential 1 unit/ 10 acres where possible Diversified Rural 4 units / 40 acres Agricultural 1 unit / 40 acres Aligning land uses, development patterns, and infrastructure is important at the local level, too. Orderly and efficient does not just mean wise use of regional infrastructure, it also means planning livable neighborhoods connected to places to work and play. While traditionally planning has separated residential neighborhoods from commercial and industrial areas, residents still need to access these places to meet their daily needs and to get to work. Communities should continue to consider strategic locations for integrating different uses into neighborhoods and to make it easier for more people to access parks and provide places to pick up a bag of groceries without needing to rely on a car. Compact development patterns, integrating natural resources, and local interconnected street networks all add to the livability of our communities. The region is able to provide cost-effective infrastructure and services when it is able to anticipate where, when, and to what extent regional growth will occur. The region establishes overall density expectations for communities based on their community designation, as well as expectations near transit stations. Density thresholds are based on an understanding of future regional growth, market demand in different parts of the region, existing development patterns and redevelopment opportunities, and regional policies to support the concentration of higher density growth around transit stations. Because each community and its values are unique, precisely how and where density is guided is determined by each community consistent with 10 Minn. Stat. 473.145 DRAFT FOR PUBLIC COMMENT Last revised: February 26, 2014 67 regional policies. As shown in Table 1, communities in the MUSA and the Rural Center communities are expected to plan for achieving the overall minimum average density expectations in their community across areas where new growth, development, and redevelopment. The Council recognizes that not all new development may meet the minimum standards, and conversely many other new developments may exceed the minimum standards. Setting minimum average densities to achieve provides communities with the flexibility to determine which areas might be most suited for higher and lower density developments, under the framework of meeting that overall minimum on available developable lands. All other communities in the Rural Service Area are expected to set maximum allowable densities as summarized in Table 1. Additional detail regarding density and development patterns is contained in each of the community designation strategy sections. Council Role • Advance the Metropolitan Council mission of ensuring orderly and economical development. • Develop and update regional plans to manage forecasted growth by using regional systems and land efficiently and effectively. • Coordinate major regional investment projects with local infrastructure and planning for development and redevelopment. • Promote development patterns that protect natural resources, the quality and quantity of our water resources, and our water supply. • Promote land use patterns that differentiate between urban and rural uses. • Update regional plans for water supply and pursue environmentally sound and cooperative water reuse practices, conservation initiatives, joint planning, and implementation efforts to maximize surface water infiltration to recharge groundwater supplies. • Support economic growth and development by promoting the wise use of water through a sustainable balance of surface and ground water use, conservation, reuse, aquifer recharge and other practices. • Provide efficient and high quality regional wastewater infrastructure and services. • Pursue wastewater reuse where economically feasible as a means to promote sustainable water resources. • Coordinate wastewater conveyance projects with regional park and trail system improvements where appropriate. Community Role • Plan for development to support forecasted growth at appropriate densities, as articulated in the following community designation sections, focusing growth along nodes on corridors. • Plan and develop interconnected local streets, adequate stormwater infrastructure, adequate water supply, and properly managed subsurface sewage treatment systems to support local growth forecasts. • Adopt and implement the local comprehensive plan following Council review. DRAFT FOR PUBLIC COMMENT Last revised: February 26, 2014 68 • Maintain, replace, or expand local facilities and infrastructure to meet growth and development needs. • Prepare local water supply, wellhead protection, wastewater, and local surface water plans as required by the Metropolitan Land Planning Act. • Plan land use patterns that facilitate groundwater recharge, reuse, and reduce per capita water use to protect the region's water supply. • Plan for sustainable water supply options and groundwater recharge areas to promote development in accordance with natural resources protection and efficient use of land. • Partner with other water supply providers to explore options to reduce dependence on groundwater. • Develop plans to improve conditions for and encourage walking and bicycling where appropriate. 0 11 Suburban Edge: Managing rapid growth and change The Suburban Edge includes communities that have experienced significant residential growth beginning in the 1990s and continuing to the 2010s. At least 40% of the land in these cities is developed, but significant amounts of land remain for future development. These communities generally do not have large-scale agricultural areas. The Suburban Edge includes regional and sub - regional job and activity centers, like Maple Grove's The Shoppes at Arbor Lakes, as well as more local and small scale centers, like downtown Chaska, that serve the local population. The Suburban Edge tends to have auto -oriented development and transportation patterns. Neighborhoods are often self-contained subdivisions characterized by cul-de-sacs and limited access to major thoroughfares for traffic movement. Recent development has included both subdivisions of single-family detached homes as well as townhome developments offering more options for housing affordability. Most cities in the Suburban Edge have access to regional trails and include some existing residential neighborhoods with sidewalks and connection to trails. Suburban Edge cities are seeing increasing demand for transit service from park -and -rides to regional destinations. The balance of proximity to more developed areas and a significant supply of developable land presents an opportunity for the Suburban Edge to develop new workforce housing. Locating future development close to existing urban services and infrastructure will use regional investments efficiently. Connections via roadway, transit, and trails to centers in adjacent Suburban and Urban communities will further integrate the Suburban Edge into regional fabric. Addressing walkability and expanding local trail networks is important for residential neighborhoods in order to increase connectivity in existing and new neighborhoods. With water supply issues facing many Suburban Edge communities, planning efforts should focus on how to protect water supply resources and identify viable alternative sources of water. Similarly, with much of their development yet ahead, Suburban Edge communities can protect and preserve open spaces, natural areas, and water recharge capacity within future development patterns. Based on the draft forecasts and current community designations, the Suburban Edge area will add 166,000 residents, 72,000 households and 160,000 jobs between 2010 and 2040. This represents growth of 41 percent in population, 48 percent in households and 48 percent in employment over the three decades. These numbers are approximations, provided for general illustration only, and may change during the upcoming comprehensive planning process. Designated Suburban Edge communities are: Blaine, Chaska, Cottage Grove, Inver Grove Heights*, Maple Grove, Plymouth, Savage, Shakopee, and Woodbury. *listed in this designation but also has areas in other designations. DRAFT FOR PUBLIC COMMENT Last revised: February 26, 2014 57 Emerging Suburban Edge. Transitioning from rural to developed The Emerging Suburban Edge includes cities, townships, and portions of both that are in the early stages of transitioning into urbanized levels of development. Strategically located between Suburban Edge and the Rural communities, the Emerging Suburban Edge communities offer both connections to urban amenities and the proximity to open spaces that characterizes a FC� rural lifestyle. Often, the cities and townships in the Emerging Suburban Edge are in more than one community designation. In the majority of Emerging t Suburban Edge communities, less than 40% of the land has been developed. Communities in the Emerging Suburban Edge have a mix of residential, rural, and agricultural areas, often including lower -density single-family neighborhoods and small downtown service centers. The growth patterns in these communities demonstrate the challenges of changing from rural to suburban. New developments are typically built in a traditional suburban pattern, characterized by large curving streets, limited through roadways, and auto -oriented street design. Emerging Suburban Edge communities have access to regional wastewater services (either municipally -owned or regional services), access to the Metropolitan Highway System, and include existing or planned regional parks system facilities. The Emerging Suburban Edge communities provide a variety of commercial activities along the main transportation corridors and most encompass historic small downtowns with small town characteristics. Commercial areas in the Emerging Suburban Edge tend to be individual large employers and smaller scale activity centers serving the local population. These communities benefit from the proximity to more developed areas while retaining their local rural character and protecting natural resources. Although these communities have some redevelopment potential in older areas such as historic downtown districts, the focus in the Emerging Suburban Edge is on greenfield development. Greenfields present opportunities to integrate natural resource preservation into site planning prior to development. Some of these communities have land available within their jurisdiction staged for future development, while others are expanding through orderly annexation agreements with neighboring townships. This mix of uses, availability of undeveloped land, and rich access to natural resources is a characteristic unique to Emerging Suburban Edge communities. Based on the draft forecasts and current community designations, the Emerging Suburban Edge area will add 228,000 residents, 105,000 households and 59,000 jobs between 2010 and 2040. This represents growth of 62 percent in population, 82 percent in households and 57 percent in employment over the three decades. Because most of the Emerging Suburban Edge communities also have rural -designated areas, these numbers are approximations. These numbers may change during the upcoming comprehensive planning process which will more precisely delineate how much community growth belongs inside the Urban Service Area. DRAFT FOR PUBLIC COMMENT Last revised: February 26, 2014 58 Designated Emerging Suburban Edge communities are: Andover*, Carver, Centerville, Chanhassen, Columbus*, Corcoran*, Dahlgren Township*, Dayton, Empire Township*, Farmington*, Forest Lake*, Greenfield*, Hastings, Hugo*, Lake Elmo*, Laketown Township*, Lakeville, Lino Lakes, Medina*, Minnetrista*, Orono*, Prior Lake, Ramsey, Rogers*, Rosemount, Spring Lake Township*, St. Paul Park, Victoria, and Waconia. *listed in this designation but also has areas in other designations. DRAFT FOR PUBLIC COMMENT Last revised: February26, 2©14 59 Suburban Edge: Managing rapid growth and change The Suburban Edge includes communities that have experienced significant residential growth beginning in the 1990s and continuing to the 2010s. At least 40% of the land in these cities is developed, but significant amounts of land remain for future development. No large-scale agricultural areas remain in the Suburban Edge. Orderly and Efficient Land Use Council Role • Support local efforts and policies to plan for growth that efficiently uses transportation and transit infrastructure and regional services. • Promote land use patterns with clear distinctions between urban and rural areas to protect natural resources and land for agricultural viability. • Provide technical assistance to communities on land use strategies and staged development to inform the local comprehensive planning process. • Partner with local communities to improve land use patterns to reduce the generation of carbon emissions. Community Role • Plan and stage development for forecasted growth through 2040 and beyond at overall average net densities of at least 3-5 dwelling units per acre in the community. Target higher intensity developments in areas with better access to regional sewer and transportation infrastructure, connections to local commercial activity centers, transit facilities, and recreational amenities. • Ensure the efficient use of land when planning for and approving new developments and redevelopment projects. Natural Resources Protection Council Role See Natural Resources policy discussion in Land Use Policy introduction. Community Role • Complete local natural resources inventories, prioritize areas to protect, and integrate natural resources conservation into local ordinances. • Conserve natural resources and protect vital natural areas when designing and constructing local infrastructure and planning land use patterns. • Encourage site planning that incorporates natural areas as part of site development and redevelopment. • Integrate water sustainability and protection of groundwater recharge areas into local plans. Consider how development, irrigation, reductions in infiltration and inflow, and DRAFT FOR PUBLIC COMMENT Last revised; February 26, 2014 99 increased surface runoff impact groundwater recharge and consider conservation strategies and best management practices to mitigate these impacts. • Implement best management practices to control and treat stormwater as redevelopment opportunities arise. Water Sustainability Council Role See Water Sustainability policy discussion in the Land Use Policy introduction. Community Rale • Incorporate best management practices for stormwater management in planning processes. • Adopt and implement best management practices for protection of natural resources, the quality and quantity of our water resources, and the preservation of water supply. • Explore alternative water supply sources to ensure adequate water resources beyond 2040. Housing Affordability and Choice Council Role See Housing Affordability and Choice policy discussion in the Land Use Policy introduction, Car11r7u.Inity Rolo • designate land in the comprehensive plan to support household growth forecasts and address the community's share of the region's affordable housing need through development and redevelopment at a range of densities, • Address the relationship of local industries to the affordability of housing in the community. • Use state, regional, and federal sources of funding and/or financing and development tools allowed by state law to assist the feasibility of the development of new lifecycle and affordable housing. • Develop or use programs to preserve the existing stock of naturally -occurring affordable housing. Access, !Mobility, and Transportation Choice Council Rale • Invest in high capacity transit and transportation improvements that support more reliable access to and from Suburban Edge communities. DRAFT FOR PUBLIC COMMENT Last revised: February 26, 2014 100 • Plan transit facilities in areas where land use is not sufficiently intense to support transit, such as park and rides, to accommodate growth and encourage the use of public transportation to regional centers. • Invest in the development and improvement of regional trails and regional bicycle corridors to better connect communities and provide viable transportation options for commuting via alternative modes. • Work with state agencies, counties, and local governments to provide assistance in planning for freight transportation to connect the rural and urban areas' markets and resources. Community Role • Develop local policies, plans, and practices that improve pedestrian and bicycle circulation, including access to regional transit services, regional trails with improved pedestrian connections, and regional bicycle corridors. • Target opportunities for intensive development in corridors or nodes along corridors, consistent with the 2040 Transportation Policy Plan. • Plan transit facilities to better incorporate alternative mode connections, such as trails and sidewalks, for facilities serving locations where commuters have to travel greater distances to complete their trip. • Work with partners in communities and counties to overcome barriers to transportation and to improve pedestrian and bicycle connections across jurisdictional boundaries. Economic Competitiveness Council Role • Promote local planning around key intersections, regional infrastructure, and business needs. • Support the development of workforce housing to provide options for lifecycle and affordable housing. • Convene interested partners to further strategies towards increasing regional competitiveness and include discussion of how Suburban Edge communities can contribute to the region's overall economic growth. Community Role • Consider how local efforts to focus economic development strategies along existing commercial centers (historic downtowns or commercial corridors) can contribute to the region's overall economic competitiveness through enhanced integration of local and regional planning efforts. • Protect sites for river- and rail -dependent manufacturing and freight transportation needs from incompatible uses and identify local land supply and transportation needs for effective use of those sites. • Identify important multi -modal intersections, alternative freight routes, key intersections, and other existing opportunities that may contribute to local and regional economic competitiveness, DRAFT FOR PUBLIC COMMENT Last revised; February 26, 2014 101 • Partner with adjacent communities and businesses to strengthen economic among subregional employment centers. • Consider best practices for workforce housing to retain employees of local employment centers within the Suburban Edge communities. Building in Resilience Council Role See Building in Resilience policy discussion in Land Use Policy introduction. Community Role • Identify local measures that would result in reductions in water use, energy consumption, and emission of greenhouse gases. • Identify local measures to address impacts to local economies, local resources, and infrastructure systems as a result of more frequent or severe weather events. • Identify mitigation and adaptation strategies and infrastructure resiliency plans to protect against potential negative impacts of events associated with more frequent or severe weather events. • Implement compact development patterns and creating more connected places to reduce auto -dependency and related generation of green house gas emissions. DRAFT FOR PUBLIC COMMENT Last revised: February 26, 2014 102 Emerging Suburban Edge: Transitioning from rural to developed The Emerging Suburban Edge includes cities, townships and portions of both that are in the early stages of transitioning into urbanized levels of development. Strategically located between Suburban Edge and the Rural communities, the Emerging Suburban Edge communities offer both connections to urban amenities and the proximity to open spaces that characterizes a rural lifestyle. Often, the cities and townships in the Emerging Suburban fudge are in more than one community designation. In the majority of Emerging Suburban Edge communities, less than 40% of the land has been developed. Orderly and Efficient Land Use Council Role • Promote land use patterns with clear distinctions between urban and rural areas to protect natural resources and land for agricultural viability. • Provide technical assistance to communities on land use strategies and staged development to inform the local comprehensive planning process. • Partner with local communities to improve land use patterns to reduce generation of carbon emissions. Community Role • Plan and stage development for forecasted growth through 2040 and beyond at overall average net densities of at least 3-5 dwelling units per acre in the community. Target higher intensity developments in areas with better access to regional sewer and transportation infrastructure, connections to local commercial activity centers, transit facilities, and recreational amenities. • Identify and protect adequate supply of land to support growth for future development beyond 2040, with regard to agricultural viability and natural and historic resources preservation. • Incorporate best management practices for storrnwater management, and natural resources conservation and restoration in planning processes. • Plan for local infrastructure needs including those needed to support future growth. Natural Resources Protection Council Role See Natural Resources Protection policy discussion in Land Use Policy introduction. Community Role • Complete local natural resources inventories, prioritize areas to protect, and integrate natural resources conservation into local ordinances. DRAFT FOR PUBLIC COMMENT Last revised: February 26, 2014 103 • Conserve natural resources and protect vital natural areas when designing and constructing local infrastructure and planning land use patterns. • Encourage site planning that incorporates natural areas as part of site development and redevelopment. Water Sustainability Council Role See Natural Resources Protection policy discussion in Land Use Policy introduction. Community Role • Incorporate best management practices for stormwater management in planning processes. • Adopt and implement best management practices for protection of natural resources, the quality and quantity of our water resources, and the preservation of water supply. Explore alternative water supply sources to ensure adequate water resources beyond 2040, • Integrate water sustainability and protection of groundwater recharge areas into local plans. Consider how development, irrigation, reductions in infiltration and inflow, and increased surface runoff impact groundwater recharge and consider conservation strategies and best management practices to mitigate these impacts. • Implement best management practices to control and treat stormwater as development and redevelopment opportunities arise. Housing Affordability and Choice �IIII:•- See Housing Affordability and Choice policy discussion in the Land Use Policy introduction. Community Role • Designate land in the comprehensive plan to support household growth forecasts and address the community's share of the region's affordable housing need through development and redevelopment at a range of densities. • Address the relationship of local industries to the affordability of housing in the community. • Use state, regional, and federal sources of funding and/or financing and development tools allowed by state law to assist the feasibility of the development of new lifecycle and affordable housing. • Develop or use programs to preserve the existing stock of naturally -occurring affordable housing. • flan for future staged growth through 2040 and beyond to accommodate a variety of housing choices based on local needs. DRAFT FOR PUBLIC COMMENT Last revised; February 26, 2014 104 Access, Mobility, and Transportation Choice Council Role • Invest in high capacity transit and transportation improvements that support more reliable access to and from Suburban Edge communities. • Plan transit facilities in areas where land use is not sufficiently intense to support transit, such as park and rides, to support growth and encourage the use of public transportation to regional centers, • Invest in the development and improvement of regional trails and regional bicycle corridors to better connect communities and provide viable transportation options for commuting via alternative modes. • Work with state agencies, counties, and local governments to provide assistance in planning for freight transportation to connect the rural and urban areas' markets and resources, Community Role • Develop local policies, plans, and practices that improve pedestrian and bicycle circulation, including access to regional transit services, regional trails with improved pedestrian connections, and regional bicycle corridors. • Target opportunities for intensive development in corridors or nodes along corridors, consistent with the 2040 Transportation Policy Plan. • Plan transit facilities to better incorporate alternative mode connections, such as trails and sidewalks, for facilities serving locations where commuters have to travel greater distances to complete their trip. • Work with partners in communities and counties to overcome barriers to transportation and to improve pedestrian and bicycle connections across jurisdictional boundaries. Economic Competitiveness '3.1>I� "10.6 R. • Promote local planning around key intersections, regional infrastructure, and business needs. • Support the development of workforce housing to provide options for lifecycle and affordable housing, • Convene interested partners to further strategies towards increasing regional competitiveness and include discussion of how Emerging Suburban Edge communities can contribute to the region's overall economic growth. Community Role • Consider how local efforts to focus economic development strategies along existing commercial centers (historic downtowns or commercial corridors) can contribute to the region's overall economic competitiveness through enhanced integration of local and regional planning efforts. DRAFT FOR PUBLIC COMMENT Last revised: February 26, 2014 105 • Protect sites for river- and rail -dependent manufacturing and freight transportation needs from incompatible uses and identify local land supply and transportation needs for effective use of those sites. • Identify important multi -modal intersections, alternative freight routes, key intersections, and other existing opportunities that may contribute to local and regional economic competitiveness. • Consider development of local employment, community, and activity centers that complement Subregional employment centers in adjacent or nearby communities and work with adjacent jurisdictions and businesses to strengthen economic relationships. • Consider best practices for developing workforce housing to attract employees of employment centers within, near, or adjacent to Emerging Suburban Edge communities. Building in Resilience Council Role See Building in Resilience policy discussion in Land Use Policy inhoduction. C0111munity Role • Identify local measures that would result in reductions in water use, energy consumption, and greenhouse gas emissions. • Identify local measures to address impacts to local economies, local resources, and infrastructure systems as a result of more frequent or severe weather events. • Identify mitigation and adaptation strategies and infrastructure resiliency plans to protect against potential negative impacts of events associated with more frequent or severe weather events. • Implement compact development patterns and creating more connected places to reduce auto -dependency and related generation of greenhouse gas emissions. DRAFT FOR PUBLIC COMMENT Last revised: February 26, 2014 106 d d d Fti a o. 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O n 2 C Q p G LL n VI Ll d d Fti a o. 3 ro � i [o +y a p a O w ❑ •2 C m E ro� m � m c i12 C_ 3 p m a ro -C c❑ o E -:R vn o n ❑ E L o a. .ro m m a 1_2c 'E = c cv m '6 W L u m N o O i2 a m =^_ Y S = 41 p, E L6 a V E U a ao+ ro C C ro -V N C - 4= C ❑ O C �0 N .Q p ro .ro � Q F V � F N Yi, 'a d � C4 � •O Y? ❑ 25 j a c � juauwdOIanaq L ia uoijeqjodsueal u c c w w c Q d m U o E E a O a 0� r❑i a �n d Fti a o. E ro � i [o o ro E � in t'i ci a p a O w ❑ •2 c "' m E ro� m � m c a m a ro E +❑'' +L+ '❑ > -:R vn o d 'rod a. .ro m m a ❑• o C f6 Q} N C -O � 0 9,] •a+F L_i7, O •y O Y Y S Q SV C N C p � 4 C C Go o B eq Q 0 .Q p ro O V O' 7 ro F V Ln 1- n O d lLL E C c juauwdOIanaq asn puel uoijeqjodsueal Metro Cities Potential Points for Inclusion ---Response to Thrive MSP 2040 Support: + Document is forward looking and visionary • Acknowledges the many assets of the region and role region as economic driver • Comprehensive identification of regional challenges and opportunities (infrastructure needs, population changes, need for economic competitiveness as a region, et al) • Recognizes need to plan for, rather than being reactive to, regional challenges + Acknowledges that much of Council's work must be done in partnership with local governments and other stakeholders • Attempts to use a shared vision/values to set goals for regional challenges and opportunities • Recognizes the importance of Met Council's role as a `convener' + Notes the importance of balancing investments across the region, making sure no one area is consistently favored or ignored and acknowledges need to balance regional concerns with local goals and circumstances + Community Designations — more specificity identifies the diversity of communities and their needs and characteristics • Support including preserving existing housing stock as part of an affordable housing policy/strategy (under outcome of Equity) Concerns: It is hard to argue with much of the statements and positions in the document --- much of it is very general, says the appropriate things about the need for a strong region, solid infrastructure, good transportation networks, natural resource protection, the need to be economically competitive etc. A theme/question that emerges is how the Council will proceed in implementing the goals outlined in the guide, and the balance between the work of the Council and its local partners. Our response should emphasize that cities are the key constituency of the Council and the key `implementers' of any regional vision, and the importance of balancing what is in the purview of the Council with the role of local governments, the importance of continued collaboration and partnering, etc. Document largely does not address how the Council will measure its performance for outcomes and goals—Metro Cities should encourage the Council to include some long term performance measures, supplemented by more specific goals in other documents – for its goals and performance; these should be transparent and understandable to the Council's local governments and partners that will help implement a regional vision/goals • The Council's interests in terms of economic competitiveness, land use, etc, should be general than specific. How will the expectations of the Council intersect with individual local goals, priorities, etc? Several areas of the document suggest a more hands on approach by the Council with respect to some issues. Moves away from one -size -fits -all which is positive (community designations, notes special features of region, etc) --- but appears in other areas to be aiming priorities for investment and infrastructure on particular areas. Council's task is to provide a guide for the orderly development of the region as a whole, which means balancing needs between new development and redevelopment. The Council's role in economic competitiveness should be for the most part to do what it does now—provide regional level infrastructure at a cost effective level of scale -- wastewater, transit (including investing in park and rides in less dense areas), parks – and continue to operate its LCA grant program in a manner that allows the program to continue to meet broad goals that enhance the region's tax base, land clean up, mixed uses, etc. The Council must also be a more active partner in advocating for resources for infrastructure and tools that can help foster economic development and redevelopment in the region. Would suggest that the Council's role is not to necessarily compile local sites for redevelopment, etc. • Breaking down silos sounds like a good idea. But challenges may lie with the proverbial devil in the details. There is a need for more analysis of these issues and their various intersections with state statutes, etc. The document outlines plans for expanded technical assistance, inventories and analyses, identifies infrastructure needs, and the like, but largely does not identify resources, or the Council's role with respect to procuring them. Our response should stress caution to the Council that it not be overly constraining in its use of existing programs (ie LCA) and should not use user -fee structures to subsidize particular goals that could serve to undermine fairness and equity in its fees, grant programs, etc. We have concern that there are several areas of the document that imply the Council may require additional comprehensive plan elements and more intrusion into local planning processes.