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dedication. A payment in lieu is based on “the fair market value of the undeveloped land.” The fair market value may be determined by a professional appraiser hired by the City Council. The ordinance also allows the City to take into consideration “the open space, recreational or common areas and facilities which the subdivider has provided for the exclusive use of the residents of the subdivision.” While the ordinance is slightly different from the statute, it is generally consistent with the law. Park dedication formula Section 462.358, subdivision 2b does not specify a maximum dedication requirement. The percentage of land in the subdivision to be committed to the public purpose is within the prerogative of the city council and will not be disturbed where reasonable. The determination of what is reasonable has been left to judicial interpretation. The leading case in Minnesota is Collis v. City of Bloomington, 246 N.W.2d 19 (1976), where developers challenged the constitutionality of Section 462.358 and Bloomington ordinance adopted pursuant to that section authorizing the city to require dedication of 10% of the undeveloped land or its equivalent in cash based on the market value as determined by the city assessor.1 The Minnesota Supreme Court upheld both the statute and Bloomington’s ordinance as constitutional. As a result, many cities adopted ordinances that generally permit park dedication amount at or up to 10%. However, it is important to understand that the Collis court did not hold that a 10% requirement is always reasonable. Rather, it upheld a 10% dedication requirement only as it applied to the particular circumstances of the proposed subdivision in that case. The court further noted that while the city has apparently made a record in this case showing that 10 percent is not unreasonable as to the property of these plaintiffs, given the particular needs of Bloomington, a 10-percent requirement might be arbitrary as a matter of law because it does not consider the relationship between this particular subdivision and recreational need in the community. Based on Collis, the reasonable dedication test in Minnesota is the existence of a reasonable relationship between the approval of the subdivision and the municipality’s need for land. As the Collis court pointed out: This is, of necessity, a facts-and-circumstances test, but it is the only kind of test that will consider the myriad of factors which may bear on a municipality’s needs for certain kinds of facilities and the relationship of a particular subdivision to those needs. Therefore, reasonableness depends on “whether a given regulation constitutes so severe a burden as to be unreasonable as applied to a particular subdivider.” 1 When Collis was decided, section 462.358, subd. 2 read as follows: “The subdivision regulations may require that *** a reasonable portion of each proposed subdivision be dedicated to the public for public use as parks and playgrounds, or that the subdivider at his option in subdivisions in excess of 30 acres, contribute an equivalent amount in cash based on the undeveloped land value.” The Bloomington ordinance established that a 10% dedication requirement was reasonable.