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HomeMy WebLinkAbout9.a. Metropolitan Council Housing Policy Plan and Transportation Policy PlanMetropolitan Council's Authority The Housing Policy Plan calls for communities to require rental inspection licensing and provide incentives for affordable housing. The Transportation Policy Plan calls for the prohibition of various uses (including surface parking) within 1/4 mile of transit station and even describes the non - conforming uses that would be created by implementing the draft policy. Thrive 2040 and its policy plans are meant to provide guidance and requirements for the community's Comprehensive Plan, but the draft Housing and Transportation Policy Plans calls for policies that regulate community's ordinances, licenses and budgets. In staffs opinion these very specific, prescriptive requirements are beyond the authority of the Metropolitan Council. Specific issues are within the attached comment letters. There are a number of weeks between this City Council meeting and the comment submittal deadlines. Staff will continue to review the draft plans and will be contacting our neighboring communities and Dakota County to evaluate their comments to the draft plans. The final comment letters may be revised based on this review. If revised, staff will provide the final document to the Council for information. RECOMMENDATION Staff recommends that the City Council authorize staff to submit comments regarding the draft Housing Policy Plan and the Transportation Policy Plan. The comments are not due until the end of the month and staff has not seen the comments from our neighboring communities and Dakota County. The comment letters attached to this Executive Summary may change based on the review of the other agencies' comments. 2 September 16, 2014 Ms. Susan Haigh, Chair Metropolitan Council 390 Robert Street North St. Paul, MN 55101 RE: Draft Housing Policy Plan Dear Ms. Haigh: The purpose of this letter is to submit comments, questions and responses to the Metropolitan Council from the City of Rosemount on the draft Housing Policy Plan. We have reviewed the draft Housing Policy Plan and appreciate the opportunity to provide feedback, comment and questions. The City of Rosemount's comments are as follows: The Housing Policy Plan has been released without the revised Housing Performance Score survey, the methodology for determining the local affordable housing needs and the Comprehensive Plan review criteria. Similar to the Thrive 2040 document that included each individual City's population, households and employment forecasts, the Housing Policy Plan should include each City's calculated affordable housing need and the criteria being used to determine the affordable housing need for its Comprehensive Plan. Without this information (that will not be available until sometime in 2015), it is difficult to support the Housing Policy Plan (or the Transportation Policy Plan that recommends the use of the Housing Performance Score in funding decisions). On page 18, the second local role is "(r)equire rental property licensing" and on page 21, the last local role states "( p)oovide incentives ". The Housing Policy Plan is meant to provide guidance on elements required to be addressed in each City's Comprehensive Plan, but not to mandate licensing and budgets. Some Cities may choose to employ rental licensing or budget for financial assistance to affordable housing, but other Cities may not and can still provide for their share of the regional housing need. The Housing Policy Plan should not mandate ordinances, licenses or locally funded incentives. • This section states on page 56 "it is both politically and structurally challenging to leverage SAC to promote affordable housing." If this is true, the first council role should be to lobby the legislature to make the necessary statutory changes and for the Metropolitan Council make the necessary administrative changes to employ SAC to promote affordable housing. On page 57, an "Affordable Housing SAC Credit" (AHC) is explored to reduce blight in a defined Area of Concentrated Poverty. If the AHC is successful in achieving affordable housing, shouldn't AHC be available to all areas, not just Areas of Concentrated Poverty? This could be a tool that would assist in incenting affordable housing to be more balanced within the Metropolitan Area. • As established in the Housing Policy Plan, there is a connection between low wage jobs, transit, and affordable housing. Consider allowing the AHC to be employed for job creation and transit supportive facilities as well as affordable housing. • On page 74, the Housing Policy Plan considers stretching housing resources by converting grant programs in revolving loan funds. This would seriously impact local government's ability to assist in affordable housing projects. Many of the Metropolitan Council grants limit the use of funds to public infrastructure and cannot be used for private redevelopment activities. If the grants were converted to a loan program, the local government would be repaying the public infrastructure costs. With the limited resources available to the local governments, it would likely result in delaying the next affordable housing project until after the revolving loan funds are repaid and therefore reduce the number of projects that local governments can participate in. We thank you for the opportunity to comment on the draft Housing Policy Plan. We look forward to working with the Metropolitan Council on revising and creating a Housing Policy Plan that will address the housing needs of a growing Rosemount and a growing region. Sincerely, William H. Droste Mayor September 16, 2014 Ms. Susan Haigh, Chair Metropolitan Council 390 Robert Street North St. Paul, MN 55101 RE: Draft Transportation Policy Plan Dear Ms. Haigh: The purpose of this letter is to submit comments, questions and responses to the Metropolitan Council from the City of Rosemount on the draft Transportation Policy Plan. We have reviewed the draft Transportation Policy Plan and appreciate the opportunity to provide feedback, comment and questions. The City of Rosemount's comments are as follows: The Transportation Policy Plan has been released without identify the funding needed to accommodate the growth projected within the Thrive 2040 household and employment forecasts. Thrive 2040 and the Transportation Policy Plan calls for focusing growth in support of multimodal travel, encourages local land use design to integrate highways and supports an appropriately spaced highway network, but the plan does not can for the regional transportation funding necessary to achieve these goals. Similarly, the Transportation Policy Plan has specific policies that emphasize transit. Table A -1 states that 33% of the vehicle miles traveled by buses occur on "A" Minor Arterials and 47% bus miles on lesser highways and local roads. Expanding transit into suburban and suburban edge communities will also require the appropriate investments in new minor arterials and lessor roads. It is unreasonable to expect that communities can adequately plan for their growth if the regional transportation investments needed to accommodate that growth are not provided. The Transportation Policy Plan calls for the prohibition of various uses (including surface parking) within 'Amile of transit station and even describes the non - conforming uses that would be created by implementing the draft policy. Thrive 2040 and its policy plans are meant to provide guidance and standards for the community's Comprehensive Plan; but the draft Transportation Policy Plan calls for policies that regulate community's ordinances and changes currently conforming businesses into non - conforming uses. In the City's opinion these very specific, prescriptive requirements are beyond the authority of the Metropolitan Council. • The Transportation Policy Plan focuses more in equity issues than in the past. It is our understanding that equity criteria will be used for future federal funding of transportation projects. Information on the criteria is not available for review and comment. Care must be taken when developing the criteria so there is a not a bias to direct funding to specific areas within the Metropolitan Area. There continues to be the expectation that suburban communities will take on additional growth but funding opportunities to accommodate infrastructure needs is becoming scarcer. We thank you for the opportunity to comment on the draft Transportation Policy Plan. We look forward to working with the Metropolitan Council on revising and creating a Transportation Policy Plan that will address the transportation needs of a growing Rosemount and a growing region. Sincerely, William H. Droste Mayor