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Page 3 <br />Enclosure <br />Letter to Charles E. Dillerud <br />September 26, 2005, <br />aviation comments above, but the specifics of land use and development staging -timing in <br />the Village and Greenbelt areas are needed to fully evaluate implications for other metro <br />systems and how low- and moderate -cost housing opportunities will be provided. <br />Housirne <br />The City's plan as submitted needs revision and additional information to comply with <br />comprehensive plan requirements regarding low and moderate -income set forth in the Land <br />Planning Act. The city's plan states all the pre-2011 sewered growth will be in Old Village, <br />but it does not delineate any of the residential land uses that will be in place in the Old <br />Village for the balance of this decade. Because of this, the Council cannot fairly assess <br />Whether Lake Elmo is providing the opportunity for the development of new rental or <br />affordable owner -occupied housing through 2010. <br />The Land Planning Act (LPA) requires local governments to address at least two issues <br />regarding low and moderate -income housing needs in preparing their local comprehensive <br />plans. They must identify in their plan their share of the regional need for low and moderate - <br />income housing, and they must prepare an implementation section of the plan that identifies <br />how they will address this share of the regional need. The plan amendment does neither. <br />In employing the same housing goals methodology other communities used in preparing their <br />1995 comprehensive plan updates, the ! .`bunch exports LOce Elr'no to set g,gg1s cod lstentt <br />wt :t re hquslug enc 1 s idei}t had £or bt er urWnizriig coitn iumitias';n the 1*1bi ie`as <br />st St. <br />Paulslai3rlg'•s gto bb regions: T`lie plan would then identify a sufficient amount of <br />sewei`ed land guided for medium and high density development pre-2011 to accommodate <br />those goals. <br />The Council would expect to see Lake Elmo applying its goals to the new sewered units in <br />the cty's Old Village neighborhood, and thus, guiding land there at a density that could <br />facilitate opportunities for affordable units. The be4011xnar for Laic l is 9 e1Sp pd fo its <br />But the above -noted land use planning deficiency is only a part of the LPA's housing <br />implementation plan responsibilities. The law requires the identification of the programs and <br />fiscal devices the city will use or others may use within Lake Elmo to advance affordable <br />housing pre-2011. The potential role the Washington County HRA can play in helping Lake <br />Elmo work toward its share of the region's needs could be mentioned as could the various <br />programs and development assistance tools from the Minnesota Housing Finance Agency or <br />