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HomeMy WebLinkAbout2.a. Discussion with Steven Chavez, Metropolitan Council Representative – District 15 � ROSEMOLINT EXECUTIVE SUMMARY CITY COUNCIL City Council Work Session Date: October 14, 2014 AGENDA ITEM: Discussion with Steven Chavez, AGENDA SECTION: Metropolitan Council Representative- Discussion District 15 PREPARED BY: Kim Lindquist, Community Development AGENDA NO. Director 2 , Q, ATTACHMENTS: City TPP & HPP comment letters, City APPROVED BY: Council Minutes Excerpt September 16, 2014, Metro Suburban County TPP Review Letter, Metro Cities TPP & HPP Comments September 2014, County Transit Investment Board Draft Comment letter, Dakota CDA HPP Draft Comments RECOMMENDED ACTION: Discussion Item ISSUE At the meeting on September 16`h the Council discussed the City comment letters for the draft Transportation Policy Plan (TPP) and the Housing Policy Plan (HPP) out for public comment from the Metropolitan Council.At that meeting, the Council discussed a variety of issues associated with the two policy plans but also other issues relating to the Metropolitan Council. It was asked that our Representative, Steven Chavez, be invited to an upcoming Council work session to discuss various issues. Staff has also obtained comment letters from Dakota County, the five suburban counties in the Metropolitan Area, and the Metro Cities organization. These letters and the Council minutes are attached for the Council's information. There aYe several issues that were raised by our Council and some of the other reviewing organizations. These are germane to the HPP and TPP but also relate to the philosophy of the current Metropolitan Council and its policies and implementation strategies. Belo�v is a listing of a fe�v relevant topics: Growth is projected and will occur, in the suburban areas but infrastructure funding, especially transportation-related, continues to be focused in the core and first ring suburbs. Local Governments seem to have litde input into transportation funding decisions that will have significant impact on their communities. Proposed policies would appear to result in further concentration of affordable housing,which is contrary to the goals of the Region. Cities need to respond to our residents and therefore over the 10-year time horizon circumstances change,but there is little in the planning documents that allow local flexibility in a dynamic economy. The process for review and comment of the policy plans is flawed as communities are being asked to comment before the Metropolitan Council has clarified how the policies will be unplemented. The policy plans contain directives that are beyond the scope of the Metropolitan Council and are the responsibility of Local Government. 2 RosE�ouNT ADMINISTRATION October 1, 2014 Ms. Susan Haigh, ChaiY Metropolitan Council 390 Robert Street Noxth St. Paul, MN 55101 RE: Draft TYansportation 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 dYaft Transportation Policy Plan and appYeciate 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 identifying the funding needed to accommodate the gxowth projected in the Thrive 2040 household and employment forecasts. Although Thrive 2040 and the Transpoitation Policy Plan call for focusing growth in support of multimodal travel, encouraging local land use design to integxate highways and supporting an appropriately spaced highway network, the plan does not call foY the Yegional transportation funding neccssary to achieve these goals. • Siinilarly, 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. TheYefore, expansion of transit into suburban and suburban edge communities will require the additional investments in new minor axterials and othex local roads. It is unYeasonable 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 paYking) within '/a mile of transit station and even descYibes the non-conforming uses that would be created by unplementing the draft policy. Thrive 2040 and its policy plans are meant to provide guidance and standaxds fox the community's Comprehensive Plan, but the draft Transportation Policy Plan calls for policies that regulate the community's ordinances and that change curxendy conforming businesses into non-conforming uses. This rype of directive is beyond the authoYity of the Metropolitan Council. Land use and zoning aYe the purview of the local government,which is in the best position to represent resident and community goals. • The TYansportation Policy Plan focuses moxe on equity issues than in the past. It is our undeYStanding that equity cYiteria will be used for future federal funding of tYansportation projects. Information on the criteria is not available for Yeview and comment. Care must be SPIRIT OF PR1DEl AND PROGRE55 Rosemount City Hall • 2875 145th Street West • Rosemount, MN 55068-4997 651 -423-441 1 • TDD/TTY 651 -423-621 9 • Fax 651 -423-4424 www.ci.rosemount.mn.us taken when developing the criteria so there is not a bias to ditect funding to specific axeas within the Metropolitan Area. There continues to be the expectation that subutban communities will take on additional growth but funding opportunities to accommodate infrastructure needs are becoming scarcer. A heightened emphasis on transit corridors for Metropolitan Council assistance pYOgrams continues to direct more funding away from growing communities. • Equity issues as translated into the Housing Performance Scores will be used for determining future highway projects through the fedeYal solicitation process. The Metropolitan Council has not deteYmined what criteria will be used in the survey and how it will be measured to determuie the Housing Performance ScoYe, and therefore the City cannot comment on whether the anticipated criteria are reasonable oY not. • Rosemount is an Emerging Suburban Edge communiry,which is described in Transit Market r'�rea IV. The Txansit Investment Plan states that Market IV does not suppoYt fYequent local service, that it is pYimaYily served by peak-period express service and that local trips are provided by general public dial-a-rides services. This is less service than is currendy provided to Rosemount by Minnesota Valley Transit Authority. Rosemount objects to any elements of the Transportation Policy Plan that call for less transit service to Rosemount. Additionally, since the Housing Policy Plan connects affordable housing with transit service, Rosemount expects the Metropolitan Council to match Rosemount's affordable housing goals with the level of transit service expected in Market IV. • Table F-5: Technical Investment Factors fox Setting Regional Transitway Priorities lists "(w)ater supply—suitability and local policies supporting groundwater recharge" as a possible measure. There is no nexus between ttansit and water supply. Please remove water supply from a possible consideYation when deterinining transitway pYioYities. 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 Txansportation Policy Plan that will address the transportarion needs of a growing Rosemount and a growing region. Sincexely, \ i� '; ��r. \ i `'—�'� -��-= �.,�.�-� ��-�-� ��%�� - ��.��: . William H. Dioste _� � Mark DeBettignies Vanessa Demuth Ma}�or Cot�ncil Nlcmber Council Member � r ' ���q�L�J�,��, ��,�( � ..e.�,_� , Kim Shoe-Corrigan� Jeff Weiscnsel Council Membei Council Member cc: Steven Chavez, District 15 Metxopolitan Council Representative Wendy Wulff, District 16 Metropolitan Council Representative 2 � Ros��ouNT COMMUNITY DEVELOPMENT September 26, 2U14 Ms. Susan Haigh, Chair Metropolitan Council 3)0 Robert Stieet North St. Paul, MN 55101 RE: Draft Housing Policy Plan llear Ms. Haigh: 1'he purpose of this letter is to submit coniments, qucstions and res��onses to die I�'[etropolitan Council from the Cit�� of Rosemount oti the draft Hotisulg Policy Plan. We have re�-iewed the draft Housing Polic�� Plan aiid appreciate tlie opportunit�� to pro��ide feedback. T'he Cit�� of Rosemoutit's comments are as follo�vs: � The Housuig Policy Plan has been Yeleased without the rc�rised Housuig Prrformance Score snrvey, the methodology for deterinining the local affocdablc housing needs, and t�ie Comprehensive Plaii Ye�rie�v criteria. Similai t�� tlie 1'hcive 2040 docuinent that includ�d each individual Cit��'s �opulation, households and em��lo}'Inent fotecasts, the Housing P�lic�� Plan should uiclude each Cit}''s calculated affordable housing need and the criteria being uscd to deternune the affordable housing necd for its Comprehensi�-e Plan. Without this information (that�vill not be available until soincume in 2015), it is difficult to support the HoUSUig_Policy Plan (ox the "I'Yansportation Pc>licy� Plan that recommends the tise of the Housing Performauce Score in funciing decisic�ns). • On page 18, the sccond local role is "(r)equue Yental propein� licensing" and on page 21, the last local role states "(p)rovide incentives". "Che I-Iousing Policy Plan is meant to provide guidance on elements reyuired tc� be addressect 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 tc� affordable hc�using, but other cities may- not and can still provide fot theit share of the tegional housing need. "I"he Housing Policy Plan should funcuon as a guide atid not tnandate ordinatices, licenses, or locall� funded iiicentives. Tlus type of diiecti�re, local zoning, land use, and hc.�usiug programs are tlie purvie�v of the local governinent and not the 1�1et�opolitan Couticil. • This sectioti states on page 56 "it is botli politicall�� and structiirally challenging to leveiage Sr1C to promote aEfordable housuig." If this is trtie, the first council role sliould be to lobb�- tlie legislature ro make the necessaiy statutor�� changes and for the Metropolitan Council to make the necessai-�� adiniiustrative changes to employ S��C to promote affordable housing. • On page 57, an "1-lffordable Housing S_1C Creciit" (��HC) is elplored to reduce blight in a defined i�rea of Concentrated Po��ert�•. If the ,�HC is successful iii aclue��ing affordable housing, shouldn't AHC be a�-ailable to all areas, not just ��reas of Concentrated Po�-ert��� SP1RlT OF PFZILaE1 AND PROGRF55 Rosemount City Hall • 2875 145th Street West • Rosemount, MN 55068-4997 651 -423-441 1 • TDD/TTY 651 -423-621 9 • Fax 651 -423-5203 wwui ri rncvmnunt mn uc This could be a tool that�vould assist ui incenting afforda�le housing to be more balanced witlun the I�1et�opolitan rlrea. 1'he Cin� can supPort the transfer of eristing S:1C creclits to affordable housing pro�rided that any additional costs resulting from the transfer arc not paid For by the other SAC customers. • As established iu the Hotisuig Policy I'lan, the.re is a connection bct�veen lo�v�vage jobs, transit, and affordable housing. Consider a11o�.ving die��f-IC to be emploS�ed for jol� crcatioii and transit su�poxtive facilities sis �vell as affordable hc�using. • On page 74, the Housulg Policy P1ai1 coiisiders stretchiiig housing resources by convertirig grant programs u�to revol�ring loan fiiiids. Tlus �voulci seriotisl}� impact local gavcrnment's ability to assist ui affoid�Ule housing projccts. I��Ian}' �f thc I��fcti-opolitan Council grants limit the use of funds to public infrastnicture .�nd cannot be used for private redevelopmcnt activities. If the grants �vere. converted to a lo:ui progratn, the local government would be repaying die public uifrastiuct�ire costs. Witl� the liinited resources available to the local governments, it�vould likel�� result in dela}�in�; thc nctit;�ffordable liousing project until after the revolving loan funds are repaid and therefc�re rcduce thc numbec of projects that local governments can participate in. • Overall, t�ie Housing Policy Plan sl�oulci be crcaced co provide fle:�ibility, IeCO�Ill7.111� tI11i TI1C communities in the i�letropolitan area are diffcrent arid one size will not fit all. Fuxther, given the tune hoiizon of t11e 2018-2040 Comprellensi��e Plan, the Housii�g Policy Plzn should build in an ability to be more nunble. .3s �vas e�perienced ul the last decade, the econoinic do�vnturn raised issues tliat�vcrc not anricipated �vhen the last policy plan w:�s adopted. "I'his inlbility to react adequ�tely to chan�c created impr.diments to the (:ity's developmeiit goals. We thank you for thc opportunity to cominent on th� draft Housing Policy Plan. �Ve lool: for�vard to�vorkuig widi the Metropolitan Couucil on reaisuig and creating a Housin�Policy Plan that will address the housing necds of a gro�vin� Ruseinouut a�id a gro�viiig region. i'�_� Sincerely, j _ i� ,�` �� •. , i / _ f - --� '\ ) � � r^� ���' �_�.� _�' � `'� -�--- -� G o�s?�-r„��"-'� William H. Droste �-a 1�Iack Dcl3ettignics Vanessa Demuth Nfayor Council �Iember Council Member , P � �� � > ,.� �� t :`�'i�' ' __,- � -�,�-r-�_�,--1' r �.�.'��•�k �-- � � - ' ��� _ I�un Shoe-Cotrigan� Jeff Wcisensel Couucil 1�Ie�nber �~f Council Meinber cc: Steven Chavez, District 15 llet�opolitan Council Representative �Y/endy Wulff, District 1 G 1�1et�opolitan Couucil Rc��resentative 2 EXCERPT OF MINUTES ROSEMOUNT CITY COUNCIL REGULAR MEETING SEPTEMBER 16, 2014 9.a. Metropolitan Council's Housing Policy Plan and Transportation Policy Plan Community Development Director Lindquist introduced the letters to the Metropolitan Council regarding the Housing Policy Plan and the Transportation Policy Plan. Community Development Director Lindquist noted areas where the Metropolitan Council seems to be overstepping their bounds and prescribing, rather than simply suggestive, of policy. Lindquist stated the Transportation Policy Plan also had issues to which the Met Council overreached in their plan. Some concerns revolve around funding being directed more toward inner city areas instead of to the suburbs. Community Development Director Lindquist doesn't foresee any significant changes to the letters, though they may change slightly before they are sent as we learn what other cities are saying. Council member DeBettignies asked about a disclaimer of some kind due to the lack of information and what is driving the Met Council to push this forward. Lindquist stated that the Policy Plans are part of the THRIVE 2040, which has a particular timeframe. Council member Shoe-Corrigan stated she didn't think that the letters are worded strongly enough. She has philosophical differences allowing the Met Council as a body of appointed officials to overstep their bounds by not allowing local government elected officials to formulate their own policies. Council member Weisensel stated this is an item that should be on our legislative agenda for next year. Mayor suggested discussions with our legislators should take place in October or November. Motion to Authorize staffto submit Housing Policy Plan and Transportation Policy Plan comments to the Metropolitan Council. Motion by DeBettignies. Second by Shoe-Corrigan. Ayes: Weisensel, Demuth, DeBettignies, Shoe-Corrigan, Droste Nays: 0. Motion carried. An�k� �����y ..1,1,A-�. WaSl�ing�Ori �ain�r��sorA .�' ::. ;:,_ , �, :. ,, > _ �' ` ,�,3':�,� �COl1IlL� CI�RV�R G O L N T Y "� � �� COUNTx Metropolitan suburban counties 2040 Transportation Policy Plan review �9/11/2�14 Draft} The five Minnesota s�burban counties of Anoka, Carver, Dakota, Scott and Washington have unique and common concerns related to the proposed 2040 Trar�sportation Policy Plan (TPP) and the refated Regional Solicitafiion plan. This �ocument describes the common concerns that affect the suburban counties and offers recommendations to alleviate these problems. During the review, it became apparent that three broad areas related to the 2040 TPP affect the suburban counties: I. Transportation Policy Plan Process II. Transportation Policy Plan Content lil. Regional Solicitation Seventeen concerns regarding the three areas are listed below along with recommended solutions for each, Item #1: THRIVE MSP 2040, 2040 TPP, and Regional Solicitation shoudd be developed sequentially to enable true public participation and allow one document to in#orm the next,the accepted practice for long-range pfanning and implementation. a. THRIVE MSP 2040 is intended to guide the 2040 TPP. Projects selected through the Regional Solicitation must comply with the 2040 TPP. THRIVE MSP 2040 was completed several months behind schedule and approved near the end of the TPP preparation. Furthermore, the scope and direction of the Regiona( Solicitation was already determined before THRIVE MSP 204p was adopted and the draft TPP was finished. ' � Metro Suburban County TPP Review September 11, 2014{Draft} Page 2 b. The Partner Agency Warking Group was created to help craft the 7PP during its preparation. The working group was selected without asking county boards to appoint. c. The members of the Working Group could not sysfiematicaily review the TPP without an adapted 7HRIVE MSP 2040.The Working Group simply did not have time to react to the 500-page draft of the Transportation Policy Plan before it was moved forward in the approval process. d. Technical Advisory Committee Planning was not adequately involved in the process even though this committee has the primary review responsibility for the TPF. Recommended salutlon#1; The counties urge the Counci!to pause, step back and reevaluafe the Transportarion Policy Plan as it�relates to the five �utcomes (Srewardship, Prosperity, E'quity, Livability and Sustainability) and three Principles (Int�egration, Co!laboration and AccauntabiJity)of THRIVE MSP 204Q to create a common vision for rhe entire region. ltem #2: The TPP devefopment process and timeline limited opportunities for two-way diafogue and the accelerated schedule constrained Council staff's availability to review and respond to sfiakeholder comments. a. The TPP was substantially complete in draft form priar to Thrive MSP 2040 being adapted, creating the perception of a predetermined outcome, and the impression that suggestions and input were not taken into account. The Partner Agency Working Group/Technical Advisory Committee planning comments were not addressed by the Council staff which prompted the Technical Advisory Committee to include them in the record and requesfi they be considered. Recommended solution#2: The suburban counties would Irke to work close�y with Council staff within a predefined set of rules and expectatrons, including expanded timeless to provide meaningful involvement, sa a!!have an equal voice in the process. ' � Metro Suburban CountyTPP Review September 11,2014{Draf�} Page 3 ltem #3: FHWA and 1101nDOT visions for a robust regional transportation system that meets the goals mandated by 10IIAP-21 should be inciuded in the increased revenu� scenario in the Highway Investment chapter. a. The Federal Highway Administration involvement €n developing the TPP is unclear. The seven performance goals (safety, infrastructure condition, congestion reduction, system reliability, freight movement and economic vitality, environmental sustainability and reduced project delivery defays} mandated by Moving Ahead for Pragress in the 21st Century Act (MAP-21} are virtuatly all related to the highway system. The TPP is not specific enough in how the region will meet these goals.The Highway Investment Section and Plan in particular, fail short in determining how policy for the regional highway system will meet these performance goals especially related to congestion reduction and freight movement and economic vitality. b. TPP goals and strategies are prioritized to transit and non�motorized modes of transportation, The highway vision represented in the TPP is focused on MnPASS and preservation. This represents a bleak future for the regional highway system in most counties. The TPP discourages highway expansion except for a few identified projects. The TPP coulc! be used as a way to say "no"to strategic capacity enhancements. Recammended solution#3: The suburban counties suggest FHWA review the performance standards and measures coni-ained in the TPP, particularly related to congestion reduction and freighi�movement and determine if they are sufficlent to meet the requirements of MAP-21. The Council should work with MnD07'to expand the highway vrsion and develop policy thar supports srrategic highway expansion where it is needed to assist in disrussions about funding needs. This will enhance the partnerships with local governments. Item #4: The Transportation Advisory Board must play a strong role in the preparation and approval of the TPP. a. Elected officials of the five suburban counties represent 42 percent of the population and 39 percent of the househofds in the region yet have fittle authority when it comes to determining regionai transportation policy. ' � Metro Suburban County TPP Review September 11, Z014{Draft} Page 4 b. The Transportation Advisory Board (TAB) plays a significant role in representing county and city interests related to transportation policy in the region yet the TAB does not have approval authority of the 7PP. c. Citizen members vf the TAB should provide balanced viewpoints that reflect the diverse modal needs of the metropolitan area.The representation on Trans�ortation Advisory Board and the Council prevents all transportation mades from being represented equafly. This results in TPP direction being s[cewed toward transit and non-matorized transportation modes which cannot address the future transportation needs of much of the suburban metro area population. d. Over the past few years the line nf responsibilities for the Met Council and the TAB is becoming increasingly blurred, making it more and rnore difficult ta determine where final authority belongs. Recommended solution#4: The suburban counties request that a clear separation of Met Council activities and TAB activitres be estab�rshed, rhat TAB be given final apprava! authority for the TPP, and that TAB bylaws be reviewed to determine if there is adequate elected offrcia!representarion to meet the needs o�aU communities in the region on bofh the TAS and TAB Executive Committee. 11. Transportation Policy Plan Content Item #5: tt is important that the TPP Goals, Objectives and Strategies clearly define the responsible party and enabling authority. a. Without clear authority, the plan provides direction to regional partners related to iocaf land use, operational and local transportation investment (a few examples include directing: a preservation first policy, use of Complete 5treets principles, local investment in the regional bicycle transportation network,transit focused investment, attempt to meet or exceed ADA requirements, alternatives to single- occupancy vehicles, and land use near transit faciiities.) ' � Metro Suburban County TPP Review September 11,20i4{Draft} Page 5 b. The plan contains multiple statements that are nat supported by accompanying data and are skewed to transit and non-motorized palicy (a few examples 'snclude: people want expanded transit, congestion represents econamic vitality,and focus on aperating and maintenance to stay competitive). Statements related to improving the highway system are virtually non-existent. Recommended solutlon#5: The suburban counties request that direction statements to regiona!partners or local governments that contain the words "shall," "wil!"ar "should" be reevaluated and categorized based on mandates, requiremenrs or desires. The countres request that the statements nat supporred by cited data contained in the TPA be reviewed based on facts and removed as necessary. Item #6: The Highveray Investment chapter should create a vision for a regional highway system thafi is consistent with documer�fied travel behavior and Metropolitan Council defined regional growth projecfiions. a. Goals and strategies and corresponding performance measures in the TPP don't align with travel behavior. Most performance measures relate to transit, pedestrian and bicycle goals which accaunt for 11 percent (3 percent transit, 6 percent walking, 2 percent biice) of tatal region trips compared to 84 percent by automobile. b. Goals, strategies and corresponding performance measures dan't align with regional growth patterns. THRIVE MSP 2040 documents historic and projected population, househnld and employment growth. Seventy-three percent of projected population and household growth and 59 percent of projected employment growth are predicted outside the urban and urban center communities but the non-local transportation investment does not address these projections. Recommended solution�G: The suburban counties request the opportunity to work with the Council i-o develop regiona!transportation goals and outcomes that align to trave!behavior and growth prajections. Withour such alfgnment there will be a radica!shift in how transportafion systems are built and operated which will result in severe congestion and safety issues in certain areas of the regron. Local governments wil!be forced to use their resources on high-priority prajects outside their jurlsdiction which wil!impacr their tax base and affect the qualrty of life in their communities which, in t�urn, will reduce the economic vitality of the region. � ' Metro Suburban County TPP Review September 11, 2014{Draft} Page 6 Item #7: The increased revenue scenario in the Highway Investment chapter should be expanded to articulate a vision for a robust regional highway system. a. The current revenue scenario plan predominantly focuses on MnPA55 and preservation far the regionai highway system and has limited vision refated to strategic capacity enhancements. b. The plan contains several transportation goals for preservation, safety, access, economic prosperity, healthy environment and land use without any strategies related to strategic highway expansion that can support all of these goals. c. There is not enough detai! about the principal arteriai needs in the region. The region lacks principal arterial capacity today and in the future based on established spacing guidelines, yet the TPP does not adequately address these needs. d. The regional highway needs identified in the additional revenue scenario and the needs beyond the increased revenue scenario are woefully inadequate (12 pages out of more than 500 are mostly dedicated to MnPAS5 projects).The plan does not adequately document the unfunded needs and revenue gap, anticipated congestion, planned growth constraints, or Transportation Finance Advisory Committee conciusians.There is no inventary of the multitude of investments needed on the regional highway system which is a typica! foundation of long-range transportation plans. e. The p[an daes not explain ar document the regiona! transportation needs or articulatE a vision that identifies the current and future funding gaps. f. 1'he plan does not account for "non-traditional" federal and state funding programs and projects that cauld use them such as the 7ransportation Investment Generating Economic Recovery program and the Corridors of Commerce Program. g. The TPP fails to recognize that operation of transit (buses) occur on highways which requires investment. Much or most of suburban transit runs on highways. Recommended solution#7: The suburban counties recommend enhancing the 7PP to include a comprehensive vision for the regional highway sysrem that documents the region's needs and funding gaps and identifies high-priorii�y capacity enhancement prajects beyand MnPASS and preservation that can be delivered with increased funding. Thrs vision shauld not be constrained to funding within 2040, but define what must happen in the r�gion. The TPA has an opportunity to utilize the recommendations from TFAC and � ' Metro Suburban CounCy TPP Review September 11, 2014{Draft} Page 7 other state r�nd loca!long range plans to inform the State Legislature.A list of project�s that could be accomplished with such programs should be included in the TPP. Item #8: The TPP should emphasize the importance of the "A" Minor system and non-freeway Principal Arterial to the regional highway system. The TPP should acknowledge the role of local governments in planning and building these impor�ant components of the sysfiem. a. The"A" Minor System* Evaluation Study contains important conclusions and recommendations that are not adequately represented in the TPP. (The 'A' minor arterial system generafiy provides for higher speed travel with limited at-grade access points for the purpose of local trips within the caunty and access to the principal arterial system.) For example, the study conciudes that principal arterials are MnDOT's investment priority. As a result it is investing significantly less in "A" minor arterials when compared to the seven counties.The study also recommends that the Metropolitan Council and TAB complete further analysis of this investment imbalance and develop as part of the nexl update of the Transportation Policy Plan, policies and strategies for building, managing, and impraving the regional highway system. b. There is little to no recognition of key local and trunk highway "A" minor and non- freeway principal arterial needs in the region. c. Local go�ernments are not bound by Council pvlicy for local road improvement projects unless they have federal funds or involve interch�nges or intersections on the state highway system. d. The finance section shows 5Q percent of the regional funding is from local sources and programs yet the plan does virtually nothing to document the role of the local transportation system in the reginn and the needs of the local system, particularly, the local "A" minor and principal arterial system. Recommended solurion#8: The suburban counties request that the recommendarions of the "A"Minor System Evaluatian Study be incorporated into the TPP and that the Counci! document t�he key "A"minor and non freeway principa!arteriaJ needs and funding gaps in the region in order to provide a comprehensive ptan for the regional highway system. The plan should clearly acknowledge this. � ' Metro Suburban County TPP Review September 11, 2014{Draft} Page 8 Item #9: The TPP should apply the outcomes and principles of THRIVE MSP 2040 equatly to all severa metropoiitan counties. a. Counties are#ruly Mlnnesota's subject matter experts when it comes to addressing poverty, and the causes of poverty. 8ut these policy plans demonstrate no recognition of this experience and proficiency. Additionally,the plans contain no data demanstrating the ef#ecfiiveness of the included strategies. b. The limited investment in the suburban counties and proposed policy direction in the plan wiil prevent the counties from meeting the stewardship, prosperity, equity, livability and sustainability outcomes of THR4VE MSP 2040. In particular,econornic competiveness and quality of life will be negatively impacted over time without adequate highway investment to accommodate growth and with a iand use poficy that controls development scenarios. The safety on regional and local highway systems within the suburban counties will be campromised and congestion will grow. Locaf governments wili be forced to allocate local funds to highest prioriCy transportation needs that are not under their jurisdiction.This has an impact on the county tax base and quality of life in their communities. c. The Principles of Integration, Collaboration and Accountability are intended to guide the Counc+l's work: however, collaboration cannot happen when policy direction does not have a shared outcome. Recommended solution#9: The suburban counties urge the Counci!to reevaluate the TPP as it relates to rhe five outcomes (stewardship, prosperity, equity, livability and sustainabifity) and three prrnciples (integratian, collaboration and accounta6ilityJ of THRlVE MSP 2040 to create a common vision for the region. Item #10: The TPP Highway Investment chapter shouid be expanded to acknowledge the important role that connections to suburban counties and Gr�ater Nlinnesota ptay in the regional and state econorny, a. The TPP does not recognize important resources suburban and rural counties contribute to improving and redeveloping the urban and urban centers and the entire region and State. � ' Metro Suburban County TPP Review Septembe►-11,Z014{Draft} Page 9 b. The TPP does not recognize the importance of the interregional corridor system to the region. c. The plan lacics information on critical freight connection improvements or bottleneck removal projects on highways entering the region. d. The investment poficy within the 7PP does not deCermine e#fect or consequences to the rest of the State. Recommended solution�#10: The suburban count�ies encourage the Council to identify strategic highway capacity enhancements on the regional highway system that�will remove freight bottle necks, improve freight efficiency and safety as well as ease congestlon of rhe highway system within and enterrng the region from greater Minnesota, The Council also should identify the economic impact an greater Minnesota�rom the proposed invest�ment direction in the region and adjust the directlon of the TPP as appropriate. Item #11: The TPP should highlight the importance of advancing both transportation and recreational bicycle trails. a. Counties and cities have worked for many years to develop a regional and local recreational trail system and have invested significant local ancf federal funds to these networks. b. Many county regional trails provide both recreation and transportation, paraileling the county and State roadways, yet wil! not have equa! standing when competing for funding. Regional trail networks make important connections to schools, community centers, parks, and activity centers that can be reached by bicycling and walking. c. The investment focus on the Regional Bicycle Transportatian Network will likely prohibit completion of the recreatianal trail system in counties and cities using federal funds. liecomrnended solution#11: The suburban counties request that Tier 1 Regional Bicycle Transportarion Network 6e amended to include all regionaf trails that are within the Metropolitan Urban Service Area. The TPP should explain how fhe Regional Bicycle Transporratron Network campliments the Regional Parks Policy P(an and the regianal/local � ' Metro Suburban County TPP Review September 11,2014{Draft} Page 10 recreational trails and the funding sources available to accelerate t�he development of both types of trai�s. Item # 12: The TPP land use density minimurns may discourage investment in the region's planned transit corridors. a. The minimum 20 dwelling units per acre for fixed/dedicatec! guideway exceeds FTA New Starts/5mall 5tarts guidelines of nine to fifteen dwelfing units per acre and is unrealistic for some transitway station locations. This requirement limits communities' abifity to consider input from their residents and market conditions. b. If land use density minimums are perceived to be unattainable, land owners and same communities along transit ways could potentially resist new transitways and station locations and slow the region's investment in new transit corridors. Recomrrrended solution#12: The suburban caunties recommend that the TPP use the FTA New/Starts Sma�1 Start�s land use rating and evaluation guidelines, and that land use densities along fransit ways are encouraged through grearer incentrves versus absolute density minimums. Item # 13: The TPP restricts certain types of land uses such as "surface parking lots" immediately around transit station areas. a. While the fogic behind encouraging higher densities, mixed use, and more wa{kable land use is sound,the prohibition of certain types of land use is overly restrictive. b. Local land use planning decisions are a city/county responsibility that should be made by elected officials and should not be mandated by the Metropolitan Council Recommended solufi�n#13: The suburban countres recommend that t'he TPP remove language that prahrbits certain types of land uses around transit station locations. The TPP should rncfude language to help communiries guide land uses �round transrt�sfiation locations and offer inceni�ives to build parking structures and intensify land uses to encourage increased transit use. � ' Metro Suburban County TPP Review September 11,2014{praft} Page 11 III. Regional Solicitation Item #14: The new Regional Solicitation should be written after the 2040 Transportation Policy Plan is fulty adopted. a. The direction contained in the new solicitation creates the perception of being a predetermined outcome without a completed 7PP to guide it. Item #15: The new Regional Solicitation should reflect the recomme�dations of the working groups formed to guide its development. a. TAC and TAC Funding &Programming are responsible for providing technical direction on the Regional Solicitat+on to the Transporl:ation Advisory Board, and they represent the interests of local governments; however,the scope of the Regional Solicitation was created by a steering committee with an emphasis on transit and bicycle modes. Item #16: The new Regional Solicitation should apply the outcomes of Stewardship, Prosperity, Equity, Livability and Sustainability as ou#lined in Thrive equaliy to all seven metropolitan counties. a. The 2040 TPP guides the Regional Solicitation criteria to favor urban and urban centers. b. The new solicitation does not represent atl classifications of"A" minors. Some classifications are at a disadvantage under the new criteria. c. The ftegionai Soiicitation has historically focused on solving existing highway problems �-- like safety and congestion issues-- but the new criteria rewards projects simply based on location. d. The TPP contains several equity goals and plans to exceed the Federal Interagency Working Group on Environmental Justice requirements.This has resulted in the � Metro Suburban County TPP Review September 11, 2014{Draft} Page 12 incorporation of unreasonable equity requirements into Regiona!Solicitation without adequate data to support the requirement. e. The equity criterion assigns points to projects near areas of poverty and utilizes affordable housing metrics(10 percent of total score for roadways, 12 percent for bikeways, and 20 percent for transit) but does not substantiate the conclusion that this will affect these areas in a positive way. f. The regional importance criterion favor projects near areas of high job concentrations but does not account for areas of projected regional job growth particularly in the suburban areas and beyond. g. Both these criteria put the suburban counties at a significant disadvantage for highway and transit funding through the solicitatior+. Recommended solution#14, #15 and#16: The suburban countres realize the time constraints in producing the Regiona!Solicitat�ron in time to uti/ize federal funds for fiscal years 2018 and 2019 and wil!work wifh the 7"A8 and the Council to irnprove the process over trme. Nowever, the counties do not agree with the equity and job concentration measures in the solicitation as they represent an unfair disadvantage. These measures wil! compound the negarive consequences of the Transportation Policy Plan's policy and investment strategies to suburban counties. The Counties request rhe equity and job concentrafian criteria pornts be lowered to help provide regiona!balance in allocating funding to �he "A"minor, transit and bicycle systems. ltem #17: The Equity and Housing criteria in the new Regional Solicitation should provlde an equal opportunity for all candidates to compete #ar federal funding. a. The Regional Solicitation's primary objective is to select projects for funding and the selection should be based on technical, not social criteria.The way the equity criterion is written is not fair ta all applicants and does not adequately represent the benefit and outcome of the proposed projects to the defined areas of disparity.7he criterion will likely select roadway and trail projects that will trigger adverse effects under Environmental Justice rules. b. Equity is important and a requirement of MAP-21; however,there is simply not enough technical information available#o measure equity-related benefits from projects that are not already covered under the other criteria in the salicitation. � � Metro Suburban County TPP Review September 11,2014{Draft} Page 13 c. 7he TPP daes not adequately show how the existing transitways already enhance equity or how the proposed build-out of the transitway system will further mitigate transportation issues within areas of disparity.These systems alone could meet the equity goafs of MAP-21, d. The proposed Housing Performance criterion is a community reward-based score as opposed to a transportation issue-based score.The criteria uses city housing performance scores instead of county and city scores as recommended in the Council's 2012 Guidelines for Priority Funding for Housing Performance.This provides significant advantage to Minneapolis and St Paul and significant disadvantage ta suburban counties. e. In the transit category,equity is again unfair to service that does not directly connect to Racia{ly Concentrated Areas of Poverty(RCAP)or Concentrated Areas of Poverty{CAP) locations. This criterion could negatively affect the populations it is intended to benefit— namely populations that work or are seeking empfoyment opportunities outside of the area in which they live that will not have access to those opportunities without a connection to another service line. In fact the region's employment growth over the last 20 years as described in THRIVE MSP 2040 has been almost solely outside of Mlnneapolis and St Paul (Frorn 1970 to 2010 employment grew by 20,000 in Minneapalis and St Paul and more than 240,000 in the suburban communities). People are commuting out of the urban and urban centers for work and need reliable transit to get there. This is often impossible without one or two connections. These "outbaund' service lines should be improved to provide similar level of service as"inbound" service.The proposed equity crifierion will make this harder ta do. f. The RCAP and CAP areas defined in the TPP and used in the Regional Solicitation do not include sufficient detail to cover all areas of disparity in the region. Federal requirements allow for analysis to be conducted at the block group level. Recommended solution#17: The suburban counties recommend that the Equity and Housing Performance criteria be eliminated from the Regional Solicitation for a!!roadway, multiuse rrails, and bicycle and pedestrian facility proJects and that the Equiry and Housing Performance points assigned ta transrt projects be reduced from 20 percenf to 10 percent. The counties request that the Council reevaluate rhe Equity and Hausing Performance criteria for subsequenr Regiona!Solicitatrons based on further analysis of rhe issues and benefits of transportatian projects to areas of disparities. To most effectively achieve equity goals, the counties encourage the Council to consider demographic data at rhe smallest geography allowable by Federa!law in order to identify as many pockets of concentrated poverty and populations of color as possible. Transportation Policy Plan Potential Areas of Support/Concern/Note Metro Cities, September 2014 • Plan advances a bold regional vision; is aspirational; acknowledges patential for region with new funding • Plan details two scenarios: existing-revenue and enhanced-revenue scenario; the enhanced scenario represents a doubling of current revenues -� not politically realistic. Neither existing nor enhanced revenue scenarios cover the transportation needs of the region over the next twenty years • Plan shouid be centered on a more realistic funding scenario – additional revenues but realistic, using historic trends/analysis • Plan needs to denote what progress can be made under a more realistic revenue scenario, and to outline specific priorities • Congestion is not adequately addressed. Plan is to "manage" congestion (traffic lights/signs, MNPASS) rather than "ease" congestion– �he result is more strain on local road systems with resulting traffic detours and use of local roads to bypass congested streets/highways. • Changes in land use expectations, particularly around transit sf;ations --- significant new piece in this TPP --- with potential implications for placement of regional investments depending on how closely local gover�lments adhere to zoning suggestions in plan—redevelopment cannot be "encouraged" into existence • Plan emphasizes infrastructure needs in core areas of the region; need to inake sure that plan is regionally balanced with respect to meeting needs and investments across the region ---vital to ensuring that economic development can occur, and congestion can be addressed in all areas –plan notes importance of regional balance in some places, while focusing on specific areas (core) in other areas of the plan --- - Met Council Housing Policy Plan _ Areas of Concern/Support/Note----Metro Cities, September 2014 Areas of Support: • Plan and its policy goals aim to be comprehensive and identify the varied housing needs in the region across housing type � Focus in plan on increasing technical assistance from Metropolitan Council for planning expertise, development examples and housing preservation tools. • Sharing of best practices, including the ULI Minnesota Toolbox. • Council role as a convener and the document's support for regional and sub-regional dialogues on topics like best practices and innovative poiicies. • Document makes note af barriers to affordable housing production. Con cerns: • Document lacks an executive summary, which would add clarity and focus. Discussion on the need for a regional plan should be part of ihe surnmary, rather than embedded further along in the document. � Document Chroughout notes "Mel Council roles" and "local govenunent rales". The document would benef t from a separate summary oi'government roles to add clear reference frames. A clear distinction should also be made between mandated roles and suggesied roles throughout the document. • Numeraus mentions/references to city comp plan elements. Would these be potential mandates? What are the benefits or implications? Metro Cities policies suppor� streamlining the comp plan process; numerous addi�ional elen�ents add complexity. Further analysis on adding elements, wheth�r mandatory or suggestive, is necessary. • While the drafi notes barriers to housing, it laeks a comprehensive analysis of available resources for housing. SAC waivers/credit flexibility, and funding the Inclusionary Housing Account are mentianed as possible resources. Metro Cities opposes �he use of SAC waivers to fund Council objectives. This is a key consideration for the plan that significantly informs the discussion of housing, and thus deserves note. • Support the locatian of affordable housing in residential and mixed-use neighborhoods throughout a ciiy, however,we do not support passa�e of a mandatory inclusionary housing paliey or requirement. • Defined roies and responsibilities. Cities are responsible for much oP the ground-l�vel housing policy in Minnesota. The Council, the state and federai governments, developers, and non-prafit entities, also have important roles that should be clearly defned in the document. • l�lexibility and loeal control. The plan should clearly state lhat tools and policies in support of affordablc housing are not universal; some may work in some cities and not others. The need for regional halance in funding in support of affardable housing preservation and creation should be included in the plan. Housin,�Performance Scores Support; • Recognition of tools in support of affordable housing, including prescrvation • Density hanuses • Recognition of city activity in support of affardable housing. • Kecping a housing diversity category. Concerns: • Active marketing of HPS scores. • Over-focus on local fiscal tools— subsidies, cash, renlal assistance • Expanded use of I-il'S in other Council funding decisions (Regional Solicitation, others to be determined) Allocation ofAjfardaGle Hocesin�Need Support: • In determining the methodology for the need allocation, the Council will continue to use adjustments (proxy to transit,jobs, existing housing stock, etc). The model also proposes ta use adjusted income levels (80% AMI, 6Q%, et al). Concern: • The work was doize on an expedited basis and at this point the work, and the HPP without the allocation, remain incomplete. Metro Cities cannot comment on the allocation or HPS until the methodology outcomes (the actual numbers)are provided. While the subgrou� on the allocation came to some consensus on specific factors, the group was not provided with the autcomes and therefore, we are not able to determine any large swings in numbers,unintended consequences, et al. 'N � � COURfTi�S���'�(Y�� � `jJ Anoka County Ramaey co�anry �akota County ' WashE�ogion County � �������� HQOnepfn Couo�ty Mart�opoD�t�n Courto�l . p�A�o : � , � 477 5elby Avenue � S&Int Pau{,Mianeabta 65102 � p:6b1-222-722� (f:6b7-223-5229 DRAFT September XX,2014 • Dear Chair Haigh, On behalf of the Counties Transit Improvement Board (CTIBj, I would like to thank the Metropolitan Council for working with us as you developed the draft 2040 Transportation Policy Plan (TPP) released for public comment in August. CTIB particularly ap.preciates the Councif's incorporatfon of many of the Board's previously submitted comments on the draft TPP, especially the inclusion of the CfIB Program of Projects in the current revenue scenario of the transit investment plan. We would also like to thank the Metropolitan Council members wha have been meeting with CTIB 8oard members over the past few manths to discuss issues of mutual interest. This extra time and effort resulted in a greater level of understanding between our two organizatinns. We feel confident tha�t th+s joint approach wiU Eead to a stronger long-range plan for transit expansion in the region. Through fihe Board's adopted Program of Projects Investment Strategy, CTIB wil) invest an additional $1.66 billion over the next 10 years to complete the Southwest LRT, Bottineau LRT, Orange Line BRT, Gateway BRT, Red Rock transitway, Riverview transitway and Robert Street Corridor transitway_projects, In this same time period, the Board will invest an additional $65 million in efficiency, safety, ridership and capacity improvernents to existing transitways. These Board investments, combfned with an additional$1.67 bifiion in federal funciing,$461 million in state funding and$427 million in local funding, will accelerate completion of Phase 1 of a long-range vision for a region-wide network of connected transitways that acts as a catalyst for economic development and increased svstem-wide transit ridership. We also appreciate the added recogni�ion in the most recent draft af the strong partnership betvueen CYIB and NBetropolitan Council and our joint role in transitway expansion in the Twin Cities Metropolitan Area. As the region's largest funder of transit expansion projects,the Board values its partnership with the Metropolitan Council as a transitway impler�enting agency. Together, the transit investments we fund and deliver will increase access to jobs, serve transit dependent populations, improve regional mobility and enhance transit service throughout the region. Draft Comment Cetrer for Board Discussion 1 IVotwithstanding the progress to date, CTIB has a number Qf remaining concerns about the draft TPP, and we respectfully offer the following comments. Part II:Land Use and Local Plannin�Chanter CTIB applauds the TPP's commitment to transit oriented development, and we agree that transit planning and land use planning ga hand in hand. The specific 70D planning policies described in the Land Use and Loca) Pfanning chapter raise concerns, however, that the TPP wif! establish regional polides that significantly exceed the federal capital grant program requirements for transitway projects and will adopt on a per station basis what FTA woufcE expect to see for an entire project corridor. We are very concerned that the 7PP's approach to land use sets up the Metropolitan Council's density expectations as locak pass/fail thresholds that could delay transitway projects. Density Expectations for Transitway Statlons The Land Use and Locai Planning Chapter identifies expectafions for residential density near transitway stations af a minimum of twenty (2�) dwelling units per acre for fixed/dedicated guideway (Table C2). This policy significantly exceeds FTA New Starts/Small Starts guidelines of nine (9) dwelling units per acre {to achieve a Medium rating) and is unrealfstic for some transitway station locations. Moreover, this requirement limits communities' ability to consider input resulting from robust ciVic engagement and market condltions. The Land llse and Local Planning chapter also specifies a minimum activity level of 7,000 total people, jobs or students within a %: mile of a transitway statfon (Table C-2).This translates to $,974 people,jobs ar students per square mile. This level of activity may be appropriate for urban �enter and urban environments, but is less appropriate for lower dens9ty suburban station areas, particularly those that incorporate park-and-ride facilities. Thfs proposed approach may also inadvertently encourage urban sprawl by requiring every transitway station to achie�e a uniformly high level of density. The TPP threshold exceeds FTA New Starts/Smal!Starts land use rating and evaluation guidelines,which eva{uate projects based on total employment served by fihe transit system and averag,e populatEon density within �,sauare mile of transitway stations. To achieve a medium land use rating, for e�cample, New Starts and Smafl Starts projects need to have a corridor average station density of at least 5,7fi0 people per square mile, which is much less than the TPP's target of 8,974 people per square mile far each statian. (Note that the FTA's requirement of 5,760 people per square mile translates to 4,500 people within a'/:mile radius.} The FTA's use of average station densities allows corridors to balance service to jab-rich central business districts with service to lower density residential communities.The proposed standard af 7,000 peopiE, Jobs, or students within a half-mile of each transltway statlon should be lowered to 4,500 and adapted as an average fior all stations along a transitway. The F7A's land use guidance for employment/activity fevel is applied to full carridors, not speclfic station locations, to allowr far flexihility and variat9on from praf�Comment LeCter for 8oard Discussion 2 statian to station based �n community input and market conditfons.The FTA poficy recognizes that for a project that operates between a suburban location and an urban center,that the urban center with its greater density and employment leveis wfll offset a suburban location that presentiy lacks that same population density or employment. CTBB supports the FTA's more balanced approach to planning for station area activity and density levels along the fuA length of transltway corrEdors. ProhibTted Land Uses and Design Features lmmediately Near Transit Stations The TPP identifies a set of land uses and design#eatures that are "prohibited" in the area Immediately surrounding transit statians (Table C-3, attached}. This new approach to regulating land use around sta#ions gives rise to questions of the analytic foundation for the new policy, the practicality of application throughout the region, the impacts of implementation, and finaily, and importantfy, its legality. An example land use that is "prahibited" by the TPP are surFace parking 1ots,which runs counter tq the use of park and ride lots by many of the region's existing and proposed transitways. Further, this policy ignores that development adjacent to transit occurs ove�a period of time, and preservation of property through surface parking lots enables those lats to be reserved far future economic devefopment when market conditions are appropriate t�justify structured parking. (The recent add(tion of a parking ramp at the Anoka commuter rail station is an example of this approach.} Does the phrase "lmmediately surrounding transit statians" include the transit station itself, including any surFace parking lot or structured parking facility included in a transitway project's capital budget7 If so,this new pol9cy has the potential to increase transitway capital praject costs by requiring more struc#ured parking facilities. In sum, CTIB has the following questions: What is the basis for the specific list of prohlbited actfvi#ies? Is ghere a body of substantive research supporting the Council's list? And finally, does the Council have the statutory authority �o directly regulate fand use around statians? If so, piease identi�y your authority. � CT'I� requests that the I�nd u�e gaaide0ir�es in tfte T�P conforrn t�and sup�ort the F7lA's r�quiremes�ts for Neow St�rts �nd S�veall Starts f�nding. C7°I� �Iso req�ests th� Metrop�l8�an Council �� cl�rify the b�sBs for#h� 9ist of pr�hibited aetia►8ties as v�elB �.s its �egal authority to prohibit lart¢! �ases and des6�ro feata�r�s e�ear transBt stataons. P�rt 11: Peioeitization P��cess Id��a�6�d'un t6u�Traeasit lo�v�s��ent�ir�ctavn and Pi�n Cl�apter The Board appreciates the Council's acicnowledgement that the proposed transitway prioritization process wili not be used for the purpases of determining the consistency of CTIB-sponsored projects with the adopted TPP.Certain aspects of the proposed approach are still cause for concern, however. One of the 8oard's key takeaways from the Program of Projects Study is that a region that stands together, advances together. The Denver region, for example, credits its success to having a shared regional commitment to accelerating and completing its transitway vlsion. Rather than worry about DrafC Comment Letter for Board Discussion 3 which line to build next, Denver focused on completing the entire system as quickfy as possible so the region would more quickljr benefit from amplified network effects of improved access and mobility. Projects within Denver's program of projects were primarily advanced based on technical readiness and availabiiity of funding. The Return on Investment Study sponsored by the Itasca Project emphasizes this same point by identifying the increased economic impacts that would result from an accelerated build- out of the regional transit system. Ci'IB agrees that decisions should be based an substantive technical analysis and extensive community input,and aur Board is committed to advancing transit investments Yhat stand up to rigorous scrutiny. If the purpose of the prioritization process is to develop a consistent body of information about proposed projects that will be accessible to policymakers and community members alike, then CTIB offers Its full support. This approach could be particularly helpful for those transitway modes not currentfy required to obtafn municipal or county resolutions of support prior to a project being adopted into the TPP. !f the purpose of the proposed prioritization process is to eliminate individual projects from consideration for funding or from amendment inta the TPP,then CTIB does not support its inclusion in the 1"PP. If the latter approach is the Council's intent, CTi6 remains concerned about the duplication �f effort that wou4d result from overlapptng anelysis of transit alternatives. We also have a conc�rn that the Council's prioritizatinn process wauld evaluate projects using different methodvlogles, resulting in different rldership estlmates, cost estimates or other results that would contradict the results of county led studies. Qnce again, we belfeve that it is important for the CT1B/Metropolitan Cauncil partnership to . stand together for our corridors to advance as quickly and smaothly as possible. CTIB agrees wlth the proposed "technical investment factors" as they are largely consistent with federal capital grant evaluation criteria for New Starts and SmaEl Starts projects. The specific measures, methodologies and benchmar!<s for measuring a project's afignment with the identified "technical investment factors" remains to be defined, as acknowledged by the Councii's praposed wdrk program, The "possible measures" identified in Table F-S give the impression, however,that these measures have been decided already, rather than being offered as examples. Since the Transit Investment Direction and Plan chapter indlcates that the Council intends to pursue a work program item to refine these "possible measures'" after the adoption of the TPP, the �oard requests that Cour�csY clarify its intent regardin� #he purpose of the prloritiza#ion proc�ss and that draft transitway priaritization measures be removec9 from the`�PP and be amended into the Plan Iat�r�fter the vuork pro�ram item is campleted. As the largest funder af transltway projects an the eegion, the �oard also reqaaests to participate ln the Cour�eil's praposed work program iteen related to r�finem�nt of the transitwvay prioratization proe�ss. Part ill•Glossarv�efinitians for Bus R�ni�!Transit and Transitwav The definitions of"bus rapid transit"and"transitway" included in the TPP gfossary blur the lines between mades and increase the difficulty for community members to speak consistently and knowledgably about proposed transit investments. The glossary definition of"transitway" broadens the definitian to Include th� concept of "high demand travel corridors that offer improved transit service," which may include "bus rapid transit, light rail or commuter rafl." The gfossary definition of bus rapid transit reduces the Draft Comment Letter for Soard Discussion 4 �� c emphasis upon all-day, frequent service by adding a comparison to "cammuter rail characteristics:'The glossary definition also reduces the emphasis upon having a singu{ar,defined route by adding the phrase "on the core portions of the route:' Further, the glossary definition of bus rapid transit confllcts with the de#inition of BRT provided in the Transit Investment Direction and Plan chapter, as well as the Regional Transitway Guidelines. Cl'IB is the primary local funding partner for transitway expansion in the Twin Cities, and a 50 percent partner in funding transitway operations. The Board is committed to using definitions that are consistent with federa!funding requirements so that Board policies are cleatly aligned with federal policies. Federal definitions of transitway modes emphasize the quality of the infrastructure investment,in addition to the quality of the transit service. TPP definitions should also be consistent with federa! policies and funding requirements and acknowiedge the role of fixed ar dedicated guideways and online or inline stations in assuring fast, reliable,attractive and efficient transit service. CTIB acknawledges that the Metropolitan Council is planning severa! bus-based transit improvements that will not be seeking competitive federaf funds.The Board supports the Metroplltan Councf{'s efforts to identify and impfement improvem�nts to the local bus system. CT16 requests that tYie terms used for. these local bus improvements not conflict with the defin+tions for bus rapid transit used by competitive federal capitaf grant programs in an effort to reduce local community confusion over transit terminology used in the region. Tl�e Baare� ree�a��sts that the �'PP adopst defir�itions far "trar�sitway" and "bu� rapid traresit" thet conf�rm to feder�9 p�licy a�d fundirs�requ�r�tvo�rots. part If: Bus ane!Su��rt Svstg_�m Inves�ment Plan s ctri�n a�f the Trar���n�ee�,tro��nt D�r�ctiora�nd Plan tha�ter The TPP calls for 1%growth of regular route bus service without explanatian of how a 1%expansion will be measured. Does 1% growth refer ta an expansion of overall service hours, route coverage, or the operating budget7 The Boa�d ceqaaests that the TPP Inc@ud�ars explanat6on abou�h�v+r 1%gr�vvth vwas selected,t�ow it vv'sN be etneasur�d and how that t6es to the�c�ats,strategi�s and obj�c�6ves of�he TPP. 7he TPP states that the Regional Service imprpvement Plan (RSIP) w{11 guide priorlties for bus service expansion. As th� bus system provides feeder bus service critical to transitway expansion, CTiB would appreciate the opportunity to participate in the development of the RSkP in the future. 7t�e TPP shcau�d exp0ain whm p�rtic9�at�� in tive d�veloprnent af the RSIP, �rEaeria for priorotlzatEon, �nd howr that pro�e§s wai9 be ca�d�ted o�r�e th�ra�xt two years t�it�cl�ade a8�stake6�oEeDers. There are no operating funds included in the Tabie F-7 for bus and bus system expansion. The YPP sh�ulc� irac9ude an explac�aticsn of v�rhy adddti��al operatir�g funds are v�ot needed to supp�r� th� �d�3tional$305 m690ior�On c�p6ta!fundBng#oc b�s and b�a��y�fiem�tt��r�si�n. Drajr Comment letter for 8aard Discussion S Part II; Transportation Policv Plan Strate�ies Chapter The TPP places strong emphasis on strategies. Page z4 of the pian notes that strategies wil! "identify how objectives will be mefi thraugh specific actions, including who is respansible." Part 2.B of fihe plan details over sixty sfirategies but is vague about the responsible party. In addition, there is na mention of the strategies in the Transit Investment Direction and Plan chapter. For example, Strategy F4 appears to be in direct confiict with changes made to the translt investment chapter by stating that the Counci! wll! prioritize investments in transit expansion. CTIB requests that YF'P strate�ies clea�ly indicate the r�sponsible authority. When statements a�f "will" or "shal{" ar� made,��'!B request5 that the TPP note the enabling au#hority o#th� r�spmnsible pa�Y• � Thank you for the opportunity to comment on the TPP. We look forward to continuing to work collaboratively with the Council on transitway expansion and operatfons through 2040 and beyond. Sincerely, Peter McLaughlin Counties Transit Improvement Board Chair Hennepin County Commissioner Draft Comment Letter for Board Dlscussion 6 Dako�a Caunty i228Town Centre Drive � Eagan,MN 55123 � Cammui�ity Develo�mc�ni: PHOUE651-675-4AQ4 � mo��-r�r��1 AgE'rlCy www.dakotacda.ory � �� 5eptember 23,2Q14 Susan Hai�h, Chair Metropolitan Council 39Q Raberi Street North Saint Patal, MN 55101 r;'='' >., ,i: ;,. Re: Housing Policy Plan Camments :; - DPar Chair Haigh: - ° ,� ;.,;:. Da!<ota County Community Development Agency (CDA) appreciates;the opportunity to.,comrnent on Metropolitan Counr.il's Housing Policy Pl�n drafi. The effo�ts:.of the Metropolitan Councif staff and the worlc graup members thai contributed to the pr�paration of a new regional Hausing Policy Plan are ,,..,-, appreciated. ��" The Dal<ata County CDA„8oard of;Gommission�ers�suppnrts t}�;e overall purpose af the plan--to create housrng options that�rve�peaple�n al!';Jife stages and;of a/l`economlc:�means viable chaices forsafe, stable and affordable hoii�ies. GivPn the:significance q.f the Plan and its proposed changes,the Dal<uta County CDA Board of Commiss,ioners is'providing, in#he;attached pages, our concerns and comments. Thank you for the opportunity to co�riment on the Housing Policy Plan. If you have any questions about our comments or would like c(�rificatio,r�,-.:please contact Marl< Ulfers{651-675-4432} at mulfers(��dal�oiacda.state.rnn us ::; Sincerely, � , Thomas A. Egar�,Chair Uakota County CQA Board of Commissioners cc: Marl< Ulfers, Executive Director Brandt Richardson, Dakota �ounty Manager � Attachments