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<br />Page 2 <br />permitted use. This precludes consideration for where higher density development may be most <br />optimal in a community with sufficient infrastructure to support it. <br /> <br />- Section 4 sets strict standards related to setback limits, minimum lot sizes, and maximum lot <br />coverage requirements. For example, the side setback requirement to be 7.5 feet on each side is <br />heavily prescriptive and would be unable to accommodate a city’s need for services to drainage <br />ditches, water and sewer lines. Cities requireaccess to these for maintenance and emergency <br />purposes. <br />- Lot sizes that require a 125% multiplier on existing lot size to be applied is again preclusive of <br />local decision making, may inadvertently encourage sprawl, and creates stormwater concerns <br />that cities must address under state and federal law due to impervious surface coverage. <br /> <br />- Section 4, subdivision 2 lines 3.21-3.25. We appreciate language regarding state and federal <br />environmental and historic concerns. The reference to Chapter 103B should be added, as those <br />joint water plans often apply to city stormwater management and land use designations. <br />- 4.20-4.23: Broad references to “building egress”, “light access requirements”, and undefined <br />“architectural design elements” will likely invite litigation and eliminate planning for pedestrian <br />friendly designs and buildings that do not consequentially affect neighboring properties. This <br />should be limited to façade materials and building components. <br />- 4.24-4.26: Parking requirements must be locally determinedto manage safety and spillover <br />effects <br /> <br />- Lines 4.27-5.9: HOAs: Common areas typically have common ownership requiring anHOA to <br />ensure proper and equitable management of property for maintenance and safety. Cities need to <br />be able to require an HOA to ensure that anyproperty mismanagement, neglect or dilapidation <br />do not become the responsibility of taxpayers. <br /> <br />- Section 4, Subdivision 4: Requiring cities to create an administrative approvalsprocess <br />regardless of size, resources, and staffing is not workable and should be permissive. We have <br />concerns about transparency and limiting resident input on new developments. <br /> <br />- Section 4, Subdivision 5: Overall, this language is overly broad and unclear on the definitions of <br />“performance conditions”, “fees”, or “dedications.” <br /> <br />- Section 4, Subdivision 6: Requiring a 1-1-26 effective date for interim ordinances, while also <br />disallowing cities from adopting interim ordinances is confusing and ignores the purpose of these <br />ordinances in allowing time to study the effects of local policies. <br /> <br />SF 2286 (Clark) Multifamily Housing in Commercial Districts <br /> <br />- Sections 1 & 2: Similar concerns as noted for SF 2229-Port. In addition, the language <br />prohibiting cities from considering traffic, noise or nuisance concerns for developments with less <br />than 300 units virtually excludes all Greater Minnesota housing development from these <br />considerations. <br /> <br />- Section 3: The bill requires that residential developments be permitted in any zoning district <br />allowing commercial uses other than heavy industrial and precludes stakeholder engagement. <br />This has concerning implications for a city’s ability to diversify their tax base to lift the property <br />63 <br /> <br />