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3601 Thurston Avenue
Anoka, MN 55303
763.231.5840
TPC@PlanningCo.com
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MEMORANDUM
TO: Daryl Morey
FROM: D. Daniel Licht, AICP
DATE: 29 May 2019
RE: Lakeville – Zoning Ordinance; Annual Review
TPC FILE: 135.01
BACKGROUND
The Planning Department initiates an annual review of the Zoning Ordinance, Subdivision
Ordinance, and/or City Code. The review of the City’s development regulations for 2019 is to
be undertaken in two phases. The first phase will address a general review of issues identified
in the course of ongoing administration of the City’s development regulations and review of
development applications. A second phase of work will involve legislating ordinance
amendments required to implement the 2040 Lakeville Comprehensive Plan. A work session
has been scheduled for 6 June 2019 to discuss the list of housekeeping topics compiled by City
staff during 2018 for the Phase 1 review and receive direction from the Planning Commission as
to possible amendments.
Exhibits:
Downtown Lakeville parking map
Letter on behalf of All Saints Catholic Church dated April 10, 2019
ANALYSIS
Development Fees. The City has established fees for applications required by the Subdivision
Ordinance and Zoning Ordinance intended to ensure that the costs of processing development
applications is borne by those making the request. The development fees address costs
incurred for City staff, publication of public hearings and ordinances, recording costs, and
overhead expenses. The City also charges applicants for costs incurred for planning,
engineering, and legal expenses for the review of development applications and administration
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of approved development plans, permits, and agreements. An escrow is collected at the time a
development application is submitted that the City utilizes to pay for these professional
services. The property owner is ultimately responsible for all costs incurred by the City related
to a development application, whether the request is approved or denied. If invoiced expenses
above the initial development application fee and escrow are not paid, the City has the ability
to assess the unpaid charges to the property to be paid with the property taxes.
The Subdivision Ordinance and Zoning Ordinance must be amended to clarify the City’s
certification of unpaid development application costs in consideration of the case of Great
Western Industrial Park, LLC v. Randolph Township, 853 N.W. 2d 155 (Minn. App. 2104). In that
case, after Randolph Township denied a conditional use permit application submitted by an
applicant and the applicant failed to pay the expenses incurred by the Township in processing
the application, the Township passed a resolution under Minnesota Statute 366.012 that
certified the expenses to the county auditor as an unpaid service charge to be collected with
applicant's property taxes. The Court of Appeals reversed the Township’s certification order
but indicated that the Township may have had a right to certify the unpaid costs if they had
included a provision in their land use ordinance to allow them to certify unpaid planning costs
to the applicant’s property taxes citing Minnesota Statute 462.353, subd. 4a., which states:
A municipality may prescribe fees sufficient to defray the costs incurred by it in
reviewing, investigating, and administering an application for an amendment to
an official control established pursuant to sections 462.351 to 462.364 [governing
municipal planning and development] or an application for a permit or other
approval required under an official control established pursuant to those sections.
Except as provided in subdivision 4a, fees as prescribed must be by ordinance. Fees
must be fair, reasonable, and proportionate and have a nexus to the actual cost of
the service for which the fee is imposed.
Based on the case of Great Western Industrial Park, LLC v. Randolph Township, City staff
recommends drafting amendments to Section 10-3-6 of the Subdivision Ordinance and the
Zoning Ordinance to outline the City’s established pass-through cost structure for processing
development applications and include a specific citation of Minnesota Statute § 462.353, Subp.
4a related to the property owner’s responsibility for unpaid charges.
Building Type and Construction. Section 11-17-9.F of the Zoning Ordinance defines various
types of building exterior finish materials regulated by the Zoning Ordinance. City staff
recommends moving the list of these definitions to Section 11-17-9.A of the Zoning Ordinance
so that they are more readily identified by architects and builders as they are preparing plans.
City staff believes this amendment will result in fewer plan changes required due to proposed
building exterior finishes not complying with the requirements of the Zoning Ordinance.
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Exterior Finish Materials. Architectural design, construction techniques, and exterior materials
continue to evolve and advance. The City has from time-to-time found it necessary to review
and amend its building type and construction standards set forth by the Zoning Ordinance to be
consistent with current practices and technology.
Simulated Wood Panels. Target Corporation received approval to update the exterior
of the SuperTarget building within the Timbercrest at Lakeville PUD District to
incorporate simulated wood panels as an accent material. The proposed simulated
wood is a durable material that is weather, impact, and graffiti resistant suitable for use
in commercial buildings. The simulated wood panels are installed on the exterior of the
building by anchoring brackets, which also allows single panels to be replaced as needed
for long-term maintenance. The use of the simulated wood material is complementary
to other materials and colors used for the exterior of SuperTarget, and is appropriate as
an accent for the building exterior while maintaining a high-quality masonry as the
primary material. City staff recommends adding simulated wood panels as an allowed
Grade B material within Section 11-17-9.B.2 of the Zoning Ordinance.
Wood. Section 11-17-9.B of the Zoning Ordinance defines use of wood that is naturally
suited or treated for outdoor use as a Grade D material along with smooth and scored
concrete block, and glass block. Section 11-17-9.D of the Zoning Ordinance allows use
of Grade D materials to comprise up to 10 percent of the exterior finish of commercial
buildings. The 10 percent limit on Grade D materials limits these exterior finishes to
being more of an accent treatment. Recent building proposals, particularly within
downtown Lakeville, have sought to use wood as a primary exterior finish as part of an
overall architectural character. City staff recommends reviewing the current
classification of wood as a Grade D material, either within the C-CBD or commercial
districts generally, to classify the finish as a Grade B or C material.
Yard Encroachments. Section 11-17-11.A of the Zoning Ordinance provides exceptions to
setback requirements to allow certain building elements to encroach into required setbacks.
Existing exceptions are allowed for cantilevered building elements not more than 2 feet;
Terraces, steps, decks, stoops or similar structures; residential clothes lines, arbors and trellises,
gazebos, and air conditioning or heating equipment; and a 1 story enclosed entrance not
exceeding 10 feet in width for single or two family dwellings into the required front yard. The
list of exceptions needs to be expanded to allow for disability accessible ramps to encroach into
a required setback. City staff recommends that the exception only provides for landings of a
size sufficient to allow access to and from the home. This exception would be similar to the
existing provision allowing for an enclosed building entrance, but not a full-width porch or deck
structure unless yard setbacks are met.
Storm Shelter. The greatest weather-related risk for life and property in Lakeville is from
severe storms, and specifically a tornado. A basement within a dwelling does not insure
maximum protection for occupants. Conditions occurring during the most severe storm or
tornado events may cause a structural collapse of the building into the basement that results in
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injury or death for people seeking shelter in these locations. However, seeking shelter in a
basement is generally considered to be an acceptable level of protection in this area.
City staff provided information regarding Federal Emergency Management Guidelines for storm
shelters for discussion as part of a Zoning Ordinance update in 2000. A storm shelter is not
required by the Building Code. However, establishment of a requirement for a storm shelter to
be installed is within the authority of the City to protect public health, safety and welfare as
stated in Section 11-1-1.B of the Zoning Ordinance. The City of Lakeville has required
construction of an interior room such as a bathroom or laundry room as storm shelter meeting
FEMA requirements within slab-on-grade dwellings since 2000. The City of Hugo discussed a
storm shelter requirement after a tornado struck the City in 2009, but makes provision of a
storm shelter optional for the initial buyer. The only other City within Minnesota that requires
a storm shelter for slab-on-grade homes is Otsego.
City staff has received comments from developers, particularly since the Great Recession in the
latter part of the prior decade, that the storm shelter requirement is prohibitive from a cost
standpoint and not desired by buyers. The Building Department does not track the number of
dwelling units that have been constructed with a storm shelter, but the indication that City staff
receives from developers is that they typically elect to construct dwellings with split entries or
basements that do not require the storm shelter. City staff is requesting the Planning
Commission discuss the storm shelter requirement and possible alternatives such as allowance
of:
Reinforced areas of refuge within an attached garage.
Use of a prefabricated above-grade storm shelter unit that would be installed within an
attached garage. The area of the attached garage would be required to be increased to
accommodate the storm shelter without impacting area for parking vehicles.
Use of a prefabricated below grade storm shelter that would be installed within the
garage floor with provisions addressing access and clearances.
Use of community buildings within developments such as Spirit of Brandtjen Farm or
Avonlea as areas of refuge.
Eliminate the requirement that storm shelters internal to the dwelling can only be
provided in a bathroom or laundry room.
Modifying storm shelter requirement such that builders are required to offer buyers the
option of constructing a storm shelter within slab-on-grade dwellings. Our office
recommends that there is no distinction between an amendment repealing the storm
shelter requirement and a regulation making it optional as the option to provide a storm
shelter already exists in the absence of requirement that one be constructed.
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Off-Street Parking. Section 11-19-13 of the Zoning Ordinance establishes requirements for a
minimum number of off-street parking stalls to be provided for specific uses. The off-street
parking requirements are based on parking demand studies prepared by the Institute of
Transportation Engineers, the American Planning Association, and other professional
organizations or agencies. The intent of requiring a minimum number of parking stalls is to
ensure the functionality of a site from a traffic circulation standpoint and avoid causing
congestion on adjacent public streets.
Section 11-19-7.J of the Zoning Ordinance establishes an administrative permit process to defer
construction of the required minimum number of parking stalls when it can be demonstrated
that the projected demand for off-street parking stalls will be less than the number specified by
the Zoning Ordinance. This situation is most often presented for large scale retail commercial
or industrial buildings where space within the structure is used for storage of goods. City staff
proposes that the off-street parking requirements be reviewed to establish a revised standard
for large scale retail commercial and industrial buildings to avoid the need for deferments on a
case-by-case basis.
In rare situations, the City encounters a development proposal that provides substantially more
off-street parking than required by Section 11-19-13 of the Zoning Ordinance, which is not
desirable due to construction and maintenance costs, increased stormwater runoff, loss of
greenspace, or under utilization of a site’s development potential. SuperTarget at TimberCrest
at Lakeville is an example of a retail store where the number of parking stalls provided
exceeded the number of stalls required by 167 stalls based on Target’s estimated demand for
parking on a limited number of peak shopping days per year. City staff is seeking input from
the Planning Commission on establishing an approval process for construction of off-street
parking stalls that exceed the requirements of Section 11-19-13 of the Zoning Ordinance based
on a percentage of required stalls.
The other off-street parking issue in need of review is the requirement for parking stalls within
the C-CBD District. The intended character of downtown Lakeville is to de-emphasize the need
for parking through business interchange, pedestrian connections, shared parking, and public
parking options. Section 11-19-21.A of the Zoning Ordinance states that on-street parking
stalls abutting a site may be used to satisfy the off-street parking requirement of Section 11-19-
13 of the Zoning Ordinance for businesses within the C-CBD District. Section 11-19-21.C of the
Zoning Ordinance provides for a further deferment of off-street parking requirements through
a development agreement that would require financial participation in public parking
improvements. Since 2000 when these provisions for C-CBD parking were adopted, the City has
constructed 254 public parking stalls in four separate parking lots within downtown Lakeville to
support retail, service, and office uses within the area. City staff is recommending that the
requirements for off-street parking for commercial uses within the C-CBD be reduced and/or
eliminated based on the supply of on-street and public parking that is available to promote the
desired character of downtown Lakeville.
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Loading Areas. Chapter 20 of the Zoning Ordinance establishes provisions requiring uses to
provide loading areas and addressing performance standards regarding location, surfacing,
screening, size, and circulation. Section 11-20-3 requires a specified number of loading areas
for multiple family residential, commercial, and industrial uses. Designation of loading areas
for multiple family residential uses for moving purposes or commercial uses for delivery of
goods is most often integrated as part of the overall site plan and managed by the property
owner. Loading areas for industrial uses is determined based upon the operational needs for
the specific business. City staff recommends amending the Zoning Ordinance to eliminate the
requirement for a minimum number of loading areas based on use or building area. City staff
further proposes reviewing existing performance standards related to location, access and
circulation, and screening to ensure functional site plans and operations that will not impact
adjacent properties or public streets.
Fence Construction. Section 11-21-5.C of the Zoning Ordinance requires that fences be
constructed in a “substantial, workmanlike manner and of substantial material reasonably
suited for the propose for which the fence is proposed”. City staff recommends that this
provision be revised to provide more quantifiable standards that can be understood by
property owners and better administered by City staff.
Commercial/Industrial Fences. Section 11-21-5.H.1.a of the Zoning Ordinance does not allow
fences to be erected in required front yards for commercially zoned properties. Section 11-21-
5.H.1.b of the Zoning Ordinance allows fences for industrially zoned properties to be erected in
all yards, including required front yards, up to a height of 8 feet; a fence within a required front
yard or the side yard of a corner lot abutting the street must be at least 75 percent open unless
an administrative permit is approved to allow for more solid construction. City staff
recommends reviewing the fence provisions for commercial districts to make an allowance for
fences within front yards, side yards of corner lots, or rear yards of through lots similar to that
allowed for industrial districts.
Land/Sea Containers. Section 11-22-7 of the Zoning Ordinance addresses outdoor storage of
land/sea containers and parking of semi-trailers. Section 11-22-7.A of the Zoning Ordinance
declares outdoor storage that does not comply with the provisions of this section to be a non-
conforming use that was to have been removed by 1 June 1996. Minnesota Statutes 462.357,
Subd. 1c prohibits amortization of non-conforming uses that are allowed to continue as they
were legally established by Minnesota Statutes 462.357, Subd. 1e. Section 11-22-7.A must be
revised to eliminate the reference to removal of non-conforming uses by 1 June 1996. Existing
legal non-conforming uses will be regulated by Chapter 15 of the Zoning Ordinance.
Signs. The following sign related issues are proposed for review of possible amendments:
Directional Signs. The City receives requests from large scale industrial sites to add
directional signage, especially when the site provides for separate patron/employee and
loading access. Section 11-23-7.B of the Zoning Ordinance makes allowance for 2 signs
not to exceed 4 square feet to be placed within a property for the purpose of
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accommodating directional signage. Industrial users would like to provide larger signs
that are more easily identifiable to traffic looking to access the site. City staff supports
allowing for larger signs for directional purposes to improve site access and circulation
and avoid congestion on public streets.
Temporary Signs. Section 11-23-15.G of the Zoning Ordinance makes provision for a
property to display 1 temporary sign upon a property for up to 60 days per year. City
staff recommends not allowing a site that has a dynamic display sign from obtaining a
permit for a temporary sign. The allowance of the changeable display on the dynamic
sign should allow the property adequate opportunity to communicate short term
messages that would not otherwise be possible with a static sign, thus creating a need
for a second, temporary sign.
Development Signs. Section 11-23-15.X.2 of the Zoning Ordinance allows placement of
temporary signs upon approval of a final plat for three or more lots to identify the
proposed development. The City has implemented procedures to expedite the process
for developers to start construction including allowing grading following preliminary plat
approval. So as to better communicate information about development activity, City
staff recommends amending Section11-23-15.X.2 of the Zoning Ordinance to allow
posting of development signs upon preliminary plat approval.
Utility Boxes. Section 11-23-17.O of the Zoning Ordinance prohibits “signs painted,
attached or in any other manner affixed to trees or similar natural surfaces, or attached
to utility poles, bridges, towers, or similar public structures, or public fences”. Signs
placed on utility boxes needs to be added to the list of prohibited sign locations
addressed by this clause.
Dynamic Display Signs. A letter has been submitted on behalf of All Saints Catholic
Church requesting that the City consider amending the Zoning Ordinance to allow their
property a larger sign that incorporates a dynamic display. All Saints Catholic Church is
located within a RM-1 District with two accesses to Holyoke Avenue. Section 11-23-
19.B.1.a of the Zoning Ordinance allows 1 freestanding monument sign up to 100 square
feet in area, which may include 40 square feet of non-electronic changeable copy, and
up to 10 feet in height at each site entrance from a collector or arterial street.
Section 11-23-15.T of the Zoning Ordinance allows for use of dynamic display signs on
properties zoned C-2, C-3, or P-OS District. Freestanding signs within commercial
districts and the P-OS District are limited to 100 square feet except within the I-35
corridor, so the area of the sign allowed All Saints Catholic Church is not more restrictive
under RM-1 District requirements. The basis of allowing dynamic display signs by
Zoning District is to insure a legally sound time/place regulation and avoid possible land
use compatibility issues for dynamic display signs within residential areas.
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The request from All Saints Catholic Church would involve amending the Zoning
Ordinance to make allowance for dynamic display signs for non-residential uses within
residential zoning districts accessed from collector or arterial streets that would include
religious facilities, schools, daycare uses, golf courses, and government uses or parks
operated by agencies other than the City of Lakeville.
Office Tenant Signage. The signage for office buildings having a single tenant are
addressed in Section 11-23-19 of the Zoning Ordinance for the respective zoning
districts. Signage for multiple occupancy commercial and industrial buildings are
addressed in Section 11-23-15.R of the Zoning Ordinance. Section 11-23-15.R.3.a
provides that the number of individual wall signs is limited to 1 per elevation per tenant
space (except additional sign(s) may be displayed on a second elevation for the tenant
of a corner suite or a suite that extends through the building thus having two (2)
exterior walls) provided that each tenant identified with a sign has an exclusive exterior
entrance. These standards are most applicable to commercial retail strip buildings.
However, it is becoming more common for multiple tenant office buildings with
common entry, lobby area, and elevators to have wall signs displaying major tenants.
City staff recommends consideration be given to amending the Zoning Ordinance to
allow for wall signs for individual tenants of a commercial or industrial building when
the tenant occupies a given percentage of the building area to recognize a major
presence within the building.
Prohibited Animals. Section 11-35-3.I of the Zoning Ordinance and Section 5-1-19 of the City
Code lists animals that are prohibited from being kept within the City. The City Attorney is
recommending the section be revised to indicate that only those properties that received
approval of an interim use permit prior to the effective date of the most recent amendment to
this section are allowed to keep any of the listed animals (subject to the provisions of the
interim use permit). This clarification of the prohibited animals will aid City staff in the
administration and enforcement of the regulations in the Zoning Ordinance and City Code.
Goats. Planning Department staff has received more requests over the years to allow goats on
a short term basis on private residential and commercial properties as a means to control
invasive plants such as buckthorn. Goats are defined as a farm animal that would only be
allowed to be kept on farm properties. The City of Eagan has recently adopted City Code
language regulations and a permit process to allow these animals for vegetation control
purposes. A permit is required and allows rental of goats on properties (or combined
properties) of at least half an acre. A fence enclosure is required and in most cases, goats may
be on a property no more than 30 days, up to 2 times per year. City staff is seeking direction
from the Planning Commission if a similar allowance for goats should be made in Lakeville as an
environmentally conscience means of invasive weed control.
RM-1 District Design and Construction Standards. Section 11-58-21 outlines design and
construction standards for developments within the RM-1 District. Similar design and
construction standards are adopted for developments within the RM-2, RH-1, and RH-2
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Districts. The design and construction standards are applicable to detached townhouse and
townhouse uses. Allowed uses within the RM-1 District include single family dwellings and two-
family dwellings constructed on a traditional lot to which the design and construction standards
are not intended to apply. City staff recommends clarifying that the design and construction
standards set forth in the RM-1, RM-2, RH-1, and RH-2 do not apply to single family or two
family dwellings. City staff further recommends that the requirement for guest parking stalls in
each of the respective districts be modified to allow on-street parking spaced to be counted to
satisfy the requirement applicable to detached townhouse or two family townhouse dwellings.
C-CBD District Motor Fuel Facilities. The purpose of the C-CBD district is to provide specifically
for the regulation of high intensity commercial uses located within downtown Lakeville. The
desired character for downtown Lakeville is described in the Downtown Development Guide as
a unique, identifiable and thriving business district. Section 11-74-7.L of the Zoning Ordinance
allows for motor fuel sales with or without a convenience store as a conditional use. There are
currently no motor fuel facilities within downtown Lakeville. City staff suggests that allowance
of a modern-day convenience motor fuel use is not in keeping with the desired character of
downtown Lakeville. We recommend that allowance of motor fuel uses within the C-CBD
District be repealed.
I-1 District Commercial Recreation. Commercial recreation is allowed as a conditional use
within the I-1, Light Industrial District subject to the provisions of Section 11-86-7.D of the
Zoning Ordinance. Section 11-86-7.D.5 of the Zoning Ordinance requires that the site of a
commercial recreation use be accessed from a collector street. The intent of this provision was
to locate a proposed commercial recreation use at the periphery of an industrial area to avoid
land use compatibility and traffic congestion issues. However, requiring access to a collector
street is not consistent with access management practices to insure efficient traffic movement
on the collector roadway. City staff recommends removal of the requirement for commercial
recreation uses to be accessed from a collector street. The general provisions regarding site
compatibility and street capacity reviewed as part of the conditional use permit process will
provide adequate protection that commercial recreation uses are appropriately located within
the I-1 District.
PO-S District. The purpose of the P-OS, Public and Open Space District is to provide for
facilities devoted to serving the public. It is unique in that the primary objective of uses within
this district is the provision of services, frequently on a nonprofit basis, rather than the sale of
goods or services. It is intended that uses within such a district will be compatible with
adjoining development, and they normally will be located along arterial or major collector
streets with full availability of urban services. Governmental utility buildings, public
maintenance buildings and structures for the City of Lakeville are permitted uses. Facilities for
government units other than the City are not allowed within the P-OS District. City staff
recommends making governmental administration, utility buildings, public maintenance
buildings and structures for jurisdictions other than the City allowed as a conditional use within
the P-OS District.
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CONCLUSION
City staff is providing the information outlined herein as a summary of the issues to be
reviewed during Phase 1 of the 2019 update of the City’s development regulations. City staff is
seeking consensus from the Planning Commission as to both the issues to be addressed as well
as the direction proposed for possible amendments. Based on this direction from the Planning
Commission, City staff will proceed to draft language amending the City’s development
regulations for further review and discussion by the Planning Commission and City Council.
c. Justin Miller, City Administrator
David Olson, Community and Economic Development Director
Andrea McDowell-Poehler, City Attorney
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210th Street