HomeMy WebLinkAboutCC & PC PACKET 03232015".Oil hary
(T
Joint City Council /Planning Commission Agenda
Monday, March 23, 2015
5:30 p.m.
(Food available at 5:15 pm)
1. Introductions
2. Land Use Training. Jed Burkett, Loss Control Attorney, League of
Minnesota Cities Insurance Trust
3. Pyramid
4. Expectations
5. Questions
is
IIA114I %�In
`I II,5
Land Use Training
St. Anthony Village
March 23, 2015
Pyramid of Discretion
sea Appouw.
c7
Zoning
Conditional
Uses
fi UL"UIRI'(`1kS' '
Conditional
Uses
�a
u�d
F.
Flpv�66- Lmtlosand oYaneMet NlMbOd[!
d�yyM ,'1. nM
I
i 1 I 1
1 I ( I
I L 1
II 1, I I
3
You be the quasi -Judge
• Riney am already written In ortarence
• Apply them fairly
• open Process
• Timely process
Creating a record
City must create record to support decision
If decision Is challenged, counts will review the public record
Record Should demonstrate
• city ererdeed oppreprlete level of dlaurobon
• appaed relevant standards In a raaewrcble feehlon
Application Process
• Staff review
• Planning Commission
• City Council
• Written Findings of Fact
• Don't forget the 6PDay Ruiel
4
Planning Commission
• Advises city council
• Evaluates staff Input
• Makes recommendations to council
• Subject to the open meeting law
Public Hearings
• A chance to explain and educate
• Develop a record
• Ask questions
• Respect citizens
• Calm and reassure
• Explain procedures
• Payadendm
-Avoid hostile Confrontations
Written Statement
Adopt a single written statement whenever a city makes
a quasi Judicial decision
• "Findings of fact and conclusions of law"
• identify relevant legal criteria
• sbWary sbnderbor cads pm Islons
• explain relevant facts relating to application
• Men apply to legal criterla to facts found
Judicial Review
Adult Uses
Sign Regulations
RLUIPA
Telecom
t
Disability
Group Homes
n
E3
Questions?
Call the League of Minnesota Cities
-1-80 a2S3 22
• LMCIT Land Use Loss Control
- J.d audud 65L281-1247
• Land Use Matenais on web site
• PLtQ✓/ Iln <,wpJQPa.fXLPP4UgPMPIP[IPIPyP
00
LEAGUE OF
MINNESOTA
CITIES
INFORMATION MEMO
Zoning for Religion
When considering an application for land use involving a religious institution, cities must comply with
the federal Religious Land Use and Institutionalized Persons Act (RL UIPA) law. Learn the
requirements of this law and read examples of provided by the U. S. Department of Justice of zoning
actions and ordinance language that can violate it.
RELEVANT LINKS
42 U.S.C. § 2000m et seq.
Employment Div.,
Department of Human
Resources of Ore. V. Smith,
42 U.S. 110 S. Ct. 108 L.Ed.
2°" 876 (1990).
I. Religious Land Use and Institutionalized
Persons Act (RLUIPA)
While it probably isn't every day that your city receives a land use
application for a religious use, this is still an area of planning and zoning
cities need to pay attention to. The way your city handles applications for
religious uses must comply with the federal Religious Land Use and
Institutionalized Persons Act (RLUIPA).
RLUIPA protects religious institutions from unduly burdensome or
discriminatory land use regulations. This law was passed unanimously by
Congress in 2000, after congressional hearings revealed that religious
organizations were disproportionately affected by local land use decisions.
Minority religions and start-up churches were impacted more than most.
Congress also found that religious institutions were treated worse than
comparable secular institutions and that zoning authorities were placing
excessive burdens on the ability of congregations to exercise their faith.
As a result, Congress enacted RLUIPA in an effort to protect religious
freedom, houses of worship, and religious schools. However, 10 years after
it was passed, RLUIPA remains something of a mystery to those involved in
local land use regulation
11. Origins of RLUIPA
A 1990 Supreme Court decision was the first step toward RLUIPA. Smith
was fired as a drug counselor for ingesting peyote during a Native American
ceremony. He was denied unemployment insurance by the state of Oregon
because his termination was due to felony use of a controlled substance. The
Supreme Court upheld the denial because the state ban on peyote was
neutral and generally applicable. The Smith decision led to an outcry from
religious groups that the courts were inadequately protecting the religious
practice of individuals from the impact of government programs and
policies.
This material is provided as general information and is not a substitute for legal advice. Consult your attorney for advice wnceming specific situations.
145 University Ave. West v✓.w,.lmc.org 4/112010
Saint Paul, MN 55103 -2044 (651) 281 -1200 or (800) 925 -1122 ® 2013 All Rights Reserved
RELEVANT LINKS:
42 U.S.C. § 2000bb et see.
Congress reacted in 1993 by passing the Religious Freedom Restoration Act
(RFRA), which established "strict scrutiny" of any law that substantially
burdened a religious individual or institution. A church in Texas challenged
a city historic preservation law under RFRA and in 1997 the case went all
the way to the Supreme Court. The Court struck down the application of
RFRA to state and local government, ruling it was an unconstitutional
violation of the limits of federalism. So Congress tried again, and after
unsuccessful bills in 1998 and 1999, RLUIPA became law in 2000.
III. RLUIPA prohibitions
Department of Justice
There is little guidance for compliance with RLUIPA, causing city officials,
RLUIPA Policy Statement,
Sept 2010.
planners, and attorneys to puzzle over the language of this law. The
following information from the U.S. Department of Justice provides
examples of the kinds of zoning actions and ordinance language that might
get a city into trouble with RLUIPA.
A. Infringement of religious exercise
42 U.s.C. s 2000cua).
RLUIPA bars zoning restrictions that impose a "substantial burden" on the
religious exercise of a person or institution, unless the government can show
that it has a "compelling interest" for imposing the restriction. In addition,
the restriction imposed must be the least restrictive way for the city to
further that interest.
Minor costs or inconveniences imposed on religious institutions are not
enough to trigger RLUIPA's protections. The burden must be "substantial."
Once the institution has shown a substantial burden on its religious exercise,
the city must show that the reason for imposing a restriction is "compelling."
Because the religious organizations in the following examples have
demonstrated a substantial burden on their religious exercise, and the
justifications offered by the cities in these cases are not compelling, the
cities would likely be in violation of RLUIPA.
Example: A church has applied for a variance to build a modest addition to
its building for Sunday school classes. The church demonstrated that the
addition is critical to carrying out its religious mission, that there is adequate
space on the lot, and that there would be a negligible impact on traffic and
congestion in the area. The city denied the variance.
Example: A Jewish congregation has been meeting in various rented spaces
that have proven inadequate for the religious needs of its growing
membership. The congregation purchased land and seeks to build a
synagogue. The city denied the permit, and the only reason given is "we
have enough houses of worship in this city already, and we want more
businesses."
League of Minnesota Cities Information Memo: 4/1/2010
Zoning for Religion Page 2
RELEVANT LINKS:
42 U.S. C. § 2000coft 1).
42 U.S C. § 2000cc(bx2).
42 U.S.C. § 2000cc(bx3XA).
42 U.S.C. § 2000cc(b)(3)(s).
B. Comparability to secular institutions
Under RLUIPA, religious assemblies and institutions must be treated at least
as well as non - religious assemblies and institutions. This is known as the
"equal terms" provision of RLUIPA. On its face, the ordinance below favors
nonreligious places of assembly over religious assemblies, so the following
example would be a violation.
Example: A mosque leases space in a storefront, but zoning officials deny an
occupancy permit since houses of worship are forbidden in that zone.
However, fraternal organizations, meeting halls, and places of assembly are
all permitted in the same zone.
C. Discrimination among religions
RLUIPA bars discrimination "against any assembly or institution on the
basis of religion or religious denomination." If it were proven that the
permit was denied because the applicants are Hindu, the example below
would constitute a violation.
Example: A Hindu congregation is denied a building permit despite meeting
all of the zoning code requirements for height, setback, and parking. The
zoning administrator is overheard making a disparaging remark about
Hindus.
D. Exclusion of religious assemblies
RLUIPA provides: "No government shall impose or implement a land use
regulation that totally excludes religious assemblies from a jurisdiction."
Exclusions like the example below are explicitly forbidden.
Example: A city, seeking to preserve tax revenues, enacts a law that no new
churches or other houses of worship will be permitted.
E. Unreasonable limits on houses of worship
Under RLUIPA: "No government shall impose or implement a land use
regulation that unreasonably limits religious assemblies, institutions, or
structures within a jurisdiction." The zoning scheme described below, if
proven to be an unreasonable limitation on houses of worship, would
constitute a violation.
Example: A city has no zones that permit houses of worship. The only way a
church may be built is by having an individual parcel rezoned, a process
which in that city takes several years and is extremely expensive.
League of Minnesota Cities Information Memo: 4/7/2010
Zoning for Religion Page 3
RELEVANT LINKS:
IV. Impact on zoning
It is important to recognize that RLUIPA does not shield religious
institutions from all land use regulation. A zoning ordinance can be enforced
as long as it does not discriminate against or exclude religious uses, does not
treat religious uses less favorably than comparable nonreligious uses, and
does not impose a substantial burden.
Religious land uses include places of assembly for worship such as
churches, synagogues, mosques, and temples. But, RLUIPA can also
encompass any number of associated religious activities, such as shelters,
schools, soup kitchens, and community centers.
Historically, most zoning ordinances have treated religious institutions like
any other building. They usually are subject to setbacks, height limits, and
lot size requirements. Often the impacts are limited to traffic and parking
concerns that occur at the time of regular worship services. However, some
ordinances specify zoning districts in which religious buildings are or are
not allowed, and require that performance standards be met as to parking
and site plan. Like any zoning regulation, the purpose is generally to
mitigate the impact of the land use on its neighbors.
Another traditional way of handling zoning ordinances is to treat churches
and other places of worship as uses associated primarily with residential
districts. Neighborhood churches were viewed as a classic residential use,
often located on corner lots near larger streets. But the model has changed
over time with new forms emerging. Large mega- churches draw thousands
of worshipers to shopping- center sized facilities. Conversely, smaller
storefront churches provide youth drop -in centers and religious outreach
efforts. Many zoning ordinances have not yet addressed the variety of forms
religious institutions can take.
V. Review and plan
Cities that have not reviewed their zoning ordinances for consistency with
RLUIPA might start by taking a look at how religious land uses are
currently regulated:
• Does the zoning ordinance call them out as specific land uses?
• If so, does the ordinance impose unique requirements or limit their
location to certain districts?
• How are religious land uses defined? If the ordinance uses the term
"churches" the city should consider changing to a broader definition, as
the term church can be viewed as discriminating among religions.
League of Minnesota Cities Information Memo: Page Page 4
0
Zoning for Religion
ege
RELEVANT LINKS:
Some ordinances now employ a broad definition of "places of assembly"
that include both religious and non - religious uses. This approach may go a
long way toward protecting the city from an equal terms challenge under
RLUIPA.
Cities should also consider whether the ordinance requires religious uses to
undergo any particular approval process. If the ordinance leaves the city
with significant discretion over the approval and conditions that may be
attached, a city is more likely to face a substantial burden challenge under
RLUIPA.
Some ordinances regulate places of religious assembly as a conditional use.
While a conditional use may be appropriate and may survive a challenge if
applied fairly and judiciously, cities should be wary of this practice.
Concerns a city may wish to address through a zoning approval process do
not always pertain to all places of assembly but rather are focused on
assemblies of a particular size. Consider classifying assemblies based on
scale and impact, and have sliding zoning standards that apply accordingly.
A small place of assembly may be permitted outright, yet a larger one would
be subject to specified performance standards.
While the meaning and impact of RLUIPA continues to be sorted out, cities
should remain aware of the possibility that their zoning practices may be
alleged to violate RLUIPA. Review of RLUIPA underscores the importance
of careful planning, as well as ordinance drafting and administration,
whenever a city receives a land use application for a religious use. Cities
should work closely with their planners and attorneys to navigate this
complex area of land use law.
VI. Further assistance
Jed Burkett For questions on the Religious Land Use and Institutionalized Persons Act
651.251.1247
jburkett@imc.org Imc.org and other land use situations, contact the League's Loss Control Land Use
League of Minnesota Cities. Attorney. You can learn more about land use issues in the land use section
of the League's website.
League of Minnesota Cities Infonnation Memo: 4/1/2010
Zoning for Religion Page 5
00
L- AGUE OF
MINNESOTA
CITIES
INFORMATION MEMO
Zoning Decisions
Zoning decisions are the source of controversy and confusion in many communities. Understanding a
city's zoning authority and the standards associated with various zoning tools is important in
navigating controversy and dispelling confusion. This memo discusses the nature of a city's decision -
making authority and the legal standards associated with variances, conditional use permits, and
nonconformities.
RELEVANT LINKS:
Learn more about zoning
decisions in LMC
information memos Zoning
Guide far Cities and
PlanningandZoning 101.
I. Level of authority
Zoning is a method of establishing a land use pattern by regulating the way
land is used by landowners. A zoning ordinance, comprised of text and a
map, generally divides a city into various districts and sets standards
regulating uses in each district. A city has considerably broader authority
when creating its zoning ordinance than it does when administering the same
ordinance. Consequently, it is important for a city to be aware of what
authority it is acting under whenever making a particular zoning decision.
When adopting or amending a zoning ordinance, a city council is exercising
so- called "legislative" authority. The council is advancing health, safety, and
welfare by making rules that apply throughout the entire community. When
acting legislatively, the council has broad discretion and will be afforded
considerable deference by any reviewing court. City councils are ultimately
accountable to the voters for legislative decisions.
In contrast, when applying an existing zoning ordinance, a city council is
exercising so- called "quasi-judicial" authority. The task is to determine the
facts associated with a particular request, and then apply those facts to the
legal standards contained in the zoning ordinance and relevant state law. A
city council has less discretion when acting quasi judicially, and a reviewing
court will examine whether the city council applied rules already in place to
the facts before it. In general, if the facts indicate the applicant meets the
relevant legal standard, then they are likely entitled to the approval.
Variances and conditional use permits are two commonplace zoning tools
that are quasi-judicial in nature.
This material is provided as general information and is not a substitute for legal advice. Consult your attorney for advice concerning specific situations.
145 University Ave. West vmv..lmc.org 6/1/2011
Saint Paul, MN 55103 -2044 (651) 281 -1200 or (800) 925 -1122 ® 2013 All Rights Reserved
RELEVANT LINKS:
See Appendix A: Pyramid of
discretion.
LMC information memo,
Land Use 1'nrtances.
Minn. Slat. g 462.357, sub. 6.
The amount of discretion a city has when making legislative versus quasi -
judicial decisions is represented by the planning and zoning "pyramid of
discretion." The bottom of the pyramid is where a city has the most
discretion —when creating a comprehensive plan and corresponding land
uses ordinances, such as a zoning ordinance. A city has less discretion when
making quasi-judicial decisions as represented by the middle of the
pyramid —the city is constrained by the ordinance and law that make up the
foundation below.
II. Variances
Variances are an exception to rules laid out in a zoning ordinance. They are
permitted departures from strict enforcement of an ordinance provision as
applied to a particular piece of property if enforcement would cause
"practical difficulties." Variances shall only be permitted when they are in
harmony with the general purposes and intent of the ordinance and when the
terms of the variance are consistent with the comprehensive plan. Variances
are generally for dimensional standards (such as setbacks or height limits)
and may not be used to allow a use that is prohibited in the particular zoning
district. Essentially, variances allow the landowner to break the dimensional
rules that would otherwise apply.
A. Practical difficulties
"Practical difficulties" is a legal standard set forth in state law. Minnesota
cities must apply the state statutory standard when considering applications
for variances. The statute provides that requests for variances are heard by a
body called the board of adjustment and appeals; in many smaller
communities, the planning commission serves that function. Generally, the
board's decision is subject to appeal to the city council. Under the statutory
practical difficulties standard, a city may grant a variance if the facts satisfy
the three - factor test for practical difficulties.
1. Use property in a reasonable manner
The first practical difficulties factor is that the property owner proposes to
use the property in a reasonable manner. This factor means that the
landowner would like to use the property in a particular reasonable way but
cannot do so under the rules of the ordinance. It does not mean that the land
cannot be put to any reasonable use whatsoever without the variance. For
example, if the variance application is for a building too close to a lot line,
or does not meet the required setback, the focus of the first factor is whether
the request to place a building there is reasonable.
League of Minnesota Cities Information Memo: 6/1/2011
Zoning Decisions Page 2
RELEVANT LINKS:
2. Circumstances unique to the property
The second practical difficulties factor is that the landowner's plight is due
to circumstances unique to the property not caused by the landowner. The
uniqueness generally relates to the physical characteristics of the particular
piece of property; that is, to the land and not personal considerations of the
landowner. The statute further notes that economic considerations alone
cannot create practical difficulties.
3. Maintain essential character of the locality
The third practical difficulties factor is that the variance, if granted, will not
alter the essential character of the locality. This factor generally
contemplates whether the resulting structure will be out of scale, out of
place, or otherwise inconsistent with the surrounding area.
B. Granting variances
If the facts surrounding a variance application satisfy all three of the
statutory factors, then a city may grant the variance. State statute further
provides variances shall only be permitted when they are in harmony with
the general purposes and intent of the ordinance, and when the terms of the
variance are consistent with the comprehensive plan. So, in addition to the
three- factor practical difficulties test, a city evaluating a variance application
should make findings as to:
• whether or not the variance is in harmony with the purposes and intent of
the ordinance, and
• whether or not the variance is consistent with the comprehensive plan.
Whatever the ultimate decision on a particular variance application, a city
should carefully consider each of the three factors of the statutory practical
difficulties standard. While past practice may be instructive, it cannot
replace the need for analysis of all three of the practical difficulties factors.
Cities should review their zoning ordinance for provisions relating to
variances to be sure they are consistent with the state statutory standard for
practical difficulties.
League of Minnesota Cities Information Memo. 6/1/2011
Zoning Decisions Page 3
RELEVANT LINKS:
Minn. Stat. § 462.3595.
LMC information memo,
Land Use Conditional Use
Permils.
Leam more about land use
issues in the land use section
of the League's website.
If a city finds it is issuing many variances to a particular standard, then the
city may wish to consider the possibility of amending the ordinance to
change the standard. In other words, if a city is consistently allowing
landowners to break a particular rule, perhaps the need for the rule should be
revisited. It could appear that the properties' plight was not particularly
unique, or even that there is not an underlying reasonable basis for the rule.
City councils have broad legislative authority when writing the rules, but
when evaluating a variance application cities are limited to the quasi-judicial
role of applying the state practical difficulties standards to the facts before
them.
III. Conditional and interim use permits
Conditional use permits are authorized under state law. Whether to grant or
deny a conditional use permit application is another zoning decision that is
quasi-judicial in nature. A conditional use is a use that is generally
compatible with a particular zoning district but because of hazards inherent
in the use itself or because of special problems that its proposed location
may present, the use is allowed by permit only if the special concerns are
addressed as set forth in the zoning ordinance.
The zoning ordinance typically details both the general standards that apply
to all conditional uses, and the specific conditions that apply to a particular
conditional use in a given zoning district. The conditions must be reasonable
and practical. Unlike a permitted use, which a landowner is generally
entitled to as a matter of right, a conditional use is allowed only after a
statutorily required public hearing. Reasonable conditions may be attached
to a conditional use permit based upon factual evidence contained in public
record.
City councils sometimes misunderstand the level and the nature of discretion
they have when reviewing applications for conditional use permits. If a
proposed conditional use satisfies the conditional use standards set forth in
the zoning ordinance, then generally the landowner is entitled to the
conditional use permit. The city made the legislative decision about the
appropriateness of a kind of use in a zoning district when the council
adopted the ordinance providing for the use as conditional. When
considering a conditional use permit application, the city is tasked with the
more limited quasi-judicial role of considering whether the facts of a
particular application satisfy the standards set forth in the ordinance. If the
belief is that a kind of use is unacceptable in a given zoning district, then
consider not listing the use as a conditional one in the district in the first
instance.
League of Minnesota Cities Information Memo: 6/1/2011
Zoning Decisions Page 4
RELEVANT LINKS:
Minn. slat. s 462.3595, smba. A conditional use permit is a property right that "runs with the land" so it
3, attaches to and benefits the land and is not limited to a particular landowner.
The state statute provides that a conditional use permit shall remain in effect
as long as the conditions agreed upon are observed. The attorney general has
A.G. Op. 59 -A -32 (February opined that time limits such as sunset provisions or automatic annual review
27,1990).
to include possible termination are not consistent with state law. The
attorney general explained that cities may not enact or enforce ordinance
provisions for conditional use permits which allow the city to terminate
permits regardless of whether or not the conditions agreed upon are
reserved. However, a city can certainly revoke a conditional use permit if
there is not substantial compliance with conditions, so long as the revocation
is based upon factual evidence, after appropriate notice and hearing.
If a city wishes to place time constraints on particular uses, then the
appropriate zoning tool is an interim use permit, rather than a conditional
Minn. slat. § 462.3597 use permit. A state law passed in 1989 authorizes interim use permits for a
temporary use of property until a particular date, until the occurrence of a
particular event, or until zoning regulations no longer permit it.
Cities may wish to employ interim use permits for uses that are not
consistent with the city's long term plan and vision for the particular area, or
where the use itself has a limited lifecycle. Interim use permits should be
provided for in the city's zoning ordinance. A public hearing is required
prior to issuance, and the land owner generally enters into an agreement with
the city.
Cities should periodically review their zoning ordinances to determine
whether the conditional uses listed are uses that remain appropriate for the
particular zoning district, and to make sure the conditions under which the
uses will be allowed are specifically set forth. Cities have broad legislative
discretion when establishing uses and conditions in their ordinance. But
when administering conditional uses set forth in the ordinance, cities are
acting in their more limited quasi-judicial capacity and are constrained to
applying the standards in the ordinance to the facts of a particular
application.
League of Minnesota Cities Information Memo: 611/2011
Zoning Decisions Page 5
RELEVANT LINKS:
LMC information memo,
Land Use Nonconjormities.
Minn, stat. $ 462.357, sub.
le.
IV. Nonconformities
Nonconformities are uses, structures, or lots that do not comply with the
current zoning ordinance.
A. Legal nonconformities
Legal nonconformities are those that were legal when the zoning ordinance
or amendment was adopted, in that they complied with preexisting
ordinance and law. The rights of legal nonconformities are often referred to
as grandfather rights. Legal nonconformities generally have a statutory right
to continue unless:
• the use is discontinued for more than one year, or
• the structure is destroyed by more than 50% of its assessed market value,
and no building permit is applied for within 180 days.
Legal nonconformities may be continued, including through repair,
replacement, restoration, maintenance, or improvement, but not including
expansion. There is a limitation to the continuance rights for
nonconformities in National Flood Insurance Program (NFIP) floodplain
areas. Despite their right to continue without complying with the current
zoning ordinance, it is important to keep in mind that all legal
nonconformities must generally comply with other city ordinances, such as a
nuisance ordinance or a licensing ordinance.
B. Non -legal conformities
In contrast to legal nonconformities, non -legal nonconformities are those
that were not permitted when established and they do not have the rights
associated with legal nonconformities. Before assuming a particular
nonconformity is entitled to the statutory right to continue, it is important to
consider whether the nonconformity ever complied with existing ordinance
or law.
Historically, the theory behind legal nonconformities was that the property
would eventually comply with the zoning ordinance. The statutory right to
continue was more limited, and cities could phase out nonconformities over
time through a process called amortization. Furthermore, the nonconformity
could not be upgraded or replaced, and nonconforming rights would cease if
the nonconformity was discontinued or destroyed. But in 2001, the
legislature prohibited amortization, except for adult uses. And in 2004, the
legislature both altered the rule about destruction and afforded
nonconformities the right to replacement, restoration or improvement, but
not expansion. Cities should review their ordinance provisions concerning
nonconformities and make sure they are consistent with the current state
statute.
League of Minnesota Cities Information Memo: 6/1 /2011
Zoning Decisions Page 6
RELEVANT LINKS:
League of Minnesota Cities Information Memo: 6/1/2011
Zoning Decisions Page 7
V. Creating a record
Whatever the nature of or standard for a particular zoning decision, a city
should create a record that will support it. If the city action is challenged,
courts will review the decision on the public record. The record must
demonstrate the city exercised the appropriate level of discretion and applied
the relevant standards in a reasonable fashion. It may not matter that the city
acted reasonably if the city is unable to prove its actions through the public
record.
When creating a record to support a zoning decision, every city should be
Minn. star. § 15.99.
aware of Minnesota's 60 -day rule. Under state law, a city must either
approve or deny a written request related to zoning within 60 days of the
LMC information memo, The
time it is submitted to the city. The city may extend the time period for an
60- DayRule: Minnesota's
additional 60 days, but only if it does so in writing before expiration of the
Automatic Approval Statute.
initial 60 -day period. Under the 60 -day rule, failure to approve or deny a
request within the statutory time period is deemed an approval. So it is
vitally important that cities scrutinize applications as they come in the door
to first make sure all required information is present, and then to process
those applications in an expeditious manner.
A. Public hearings
Holding a public hearing is an important component in developing the
LMC information memo,
Rabr;c Flemings,
record. Public hearings are generally required before the adoption of any
zoning ordinance or amendment, and before the granting of variances,
conditional use permits, or re- zonings
Minn. stat. s 46x357, subd.
Under state law notice of the time, place, and purpose of the hearing must be
3.
published at least 10 days prior to the day of the hearing. If the decision
affects an area of five acres or less, mailed notice may be required to
property owners within a 350 -foot radius of the land in question.
Public hearings should include a complete disclosure of what is being
proposed and a fair and open assessment of the issues raised. A public
hearing should include an opportunity for the general public and interested
parties to hear and see all the information and to ask relevant questions,
provide additional information, and express support or opposition. In order
to help the public hearing process run well, it is helpful for the city council
to develop a written set of policies and procedures to follow at each public
hearing.
League of Minnesota Cities Information Memo: 6/1/2011
Zoning Decisions Page 7
RELEVANT LINKS:
League of Minnesota Cities Information Memo: 6/1/2011
Zoning Decisions
Page 8
Neighborhood opposition is perhaps the most challenging issue for any city
council or planning commission to deal with when considering the merits of
a particular zoning application. Case law holds that the views of neighbors
should not be the sole basis for a particular city action. In this regard, it is
helpful to distinguish between what might be termed the "quantity" of the
comments, as opposed to the "quality" of the comments. For example, well -
supported testimony that brings forth relevant facts is the kind of
information upon which a city council can rely. On the other hand,
unsupported and unsubstantiated emotional opposition to a particular project
should not be the basis for a decision.
B. Written statements
After a public hearing, the city should make findings to support its decision.
In the case of a denial of a particular zoning application, Minnesota's 60 -day
rule requires the reasons for a denial be put in writing and those reasons be
adopted within the statutory timeframe. Failure to do so may result in the
city council decision being overturned. Even where the application is
approved, a written statement explaining the decision is advisable.
The written statement explaining the reasons for the zoning decision is
particularly important for quasi-judicial decisions such as variances and
LMC information memo,
Taking the Hystery Out of
conditional use permits. The League recommends the city adopt written
Findings of Fact.
findings of fact and conclusions of law whenever a city makes such
decisions. The document should identify the relevant legal criteria such as
statutory standards or code provisions, explain the relevant facts relating to
the particular application, and then apply those facts to the legal criteria. The
document should provide a court with everything needed to uphold the
zoning decision.
VI. Further assistance
Jed Burkett
Zoning decisions can be controversial and confusing, and this memo is by
651.281,1247
no means a comprehensive discussion of all issues that may arise. If you
800.925.1122
jburkett@lmc.org
have further questions relating to zoning decisions, please feel free to
contact the League's Loss Control Land Use Attorney.
When dealing with particular issues, it is also important to seek specific
legal advice from your own city attorney.
League of Minnesota Cities Information Memo: 6/1/2011
Zoning Decisions
Page 8
Appendix A: The pyramid of discretion
The pyramid framework illustrates how much discretion the city has to make land use decisions
based on the role it is playing.
Variances
1% %P-
IV Q Conditional
Use Permits F
Subdivision Applications
Zoning /Subdivision
Ordinances
Cr Comprehensive Plan
6/1,20„
League of Minnesota Cities Information Memo: page g
Zoning Decisions
2015
Mission
�ain thou
illa e C�
To be a progressive
and livable community,
a "walkable" Village which is
sustainable, safe and secure.
........................ \
VISION
"Saint Anthony is a vibrant community that values our unique
environment, our fiscal soundness and a tradition of being a desirable
city in which to live, work, learn and play."
STRATEGIC INITIATIVES
Create &Maintain
Healthy
rhootls
2 -9 -2015
"W. ,-
Implement
Explore joint
Continue
Explore
Assess new
Plan & implement
Continue grant
organized collection
fiber partnership
farmer's market
sustainable house
"SAW signs on
new technology
tracking
Continue
Complete 2015
in SAVillage
remodel project
secondary City
for all city
applications
Continue
phosphorus
street, utility and
Shopping Center
Continue
accesses
cooperative
reduction initiative
sidewalk project
Explore Cultural-
housing
Create
Update Hennepin
ventures with
Historical Center
rehabilitation
Communication
County mass
other entities
Continue Silver
DDetermine
and reinvestment
Plan
dispensing plan
Plan 2016
Lake &Mirror Lake
feasibility study
Provide more on-
clean -up
of underground
line city services
Programs
Create
Conduct
levy & street ,
utilities
from website
Conduct Council
Community
National Incident
improvemen
Continue a rain
Tour of City
Profile
Management
program
barrel &rain garden
workshop
Complete
accessible
Consider
alternative polling
Ensure city
Explore Fix -it
Systems training
(or counciVsaf(
Maintain resilient
"Green
Pedestrian signal
place (Ramsey
code reflects
Clinics
workforce ,
Become a
(APS) funding
Co)
sustainability
Continue
Continue summer
Review
Step 4 City'
Continue Mirror
Continue Night
initiatives
project update
surwal school
compensation, =
P
lore roof
gr�O
Lake area
to Unite
Pursue southern
& information
Continue crime
staffing and f
oonn water sr°age
Flooding options
Explore
"Gateway"
sheet
prevention
organizational f
Continue LED
innovative citizen
redevelopment
Explore efficient
strategies
structure
r
wood fires
lighting
engagement ideas
study
collections of
Identify traffic
Analyze/validate
impact
impact
Evaluate Code
payments
studies on major
contracts
Implement less
Track "Storm
Proofing"
Provide road
reconstruction
Enforcement
roadways &
Expand long ter m r
paper office concept
(electrical
education event
program
intersections
revenue planning
Exp lore alternate
ou tag es )
Discuss options
Enhance
Expand sharing of
energy ideas
Review adequacy,
for land use
pedestrian & bike -
major equipment
Explore organics
Exp Ban
function &size of
density /impact on
friend routes
�'
including sidewalks
r'g
items with other
public facilities
walkability
governmental
Explore urban
Assess parks
Conduct
entities
farming
Explore
roundabouts
& recreation
emergency
Continue exploring
n
Explore source
facilities
management
equipment
water access
"TableTop"
ownership vs.
planning
exercise
leasing
2 -9 -2015