VI. 1. Planning Application 2018-12-AMD 2040 Comprehensive Plan UpdateMEMO
To: Planning & Zoning Commission
From: Jason Lindahl, City Planner
Date: April 23, 2019
Subject: Cultivate Hopkins Comprehensive Plan Comment
Proposed Action
Review comments on the 2040 Comprehensive Plan Update – Cultivate Hopkins and provide
feedback. Staff will use this feedback to help draft the final version of the plan tentatively scheduled
for a public hearing before the Planning & Zoning Commission on May 28.
Overview
Attached please find all comments the City received on the Draft 2040 Comprehensive Plan Update
– Cultivate Hopkins along with a memo from Haila Maze, Senior Planner with Bolton & Menk
summarizing this information. During the meeting, staff will review this information and take
comments from the Planning & Zoning Commissions.
The attached Comment Tracker table includes comments from the open house and Planning &
Zoning Commission public hearing on August 28 through the end of the required 6 month review
period on March 12th. The table organizes comments by the four plan elements (Built, Social,
Natural and Economic) and includes both incomplete and advisory comments from the
Metropolitan Council and adjacent and effected communities. It also includes comments from the
public including Larry Hiscock (member of the comprehensive plan advisory committee), the Great
Plains Institute (an energy efficiency and environmental advocacy group), the Center for Economic
Inclusion (a group dedicated to advancing inclusive growth to achieve regional prosperity) and three
anonymous residents who submitted comments through the City’s website.
While the comments may appear vast, many are technical and have already been addressed by staff.
During the meeting, staff will focus on those items that could merit additional discussion including
revised growth projections from the Metropolitan Council, sustainability comments from the Great
Plains Institute, equity comments from the Center for Economic Inclusion, gentrification and
housing comments from Larry Hiscock and the comments submitted online.
Attachments
Summary Memo from Haila Maze, Senior Planner with Bolton & Menk
City of Hopkins Comprehensive Plan Comment Tracker
1
MEMO
To: Honorable Mayor and City Council
Planning & Zoning Commission
From: Jason Lindahl, City Planner and Haila Maze, Senior Urban Planner
Date: April 23, 2019
Subject: Cultivate Hopkins Comprehensive Plan Comments
Background and Process to Date
In the fall of 2018, the City of Hopkins completed its draft comprehensive plan update and released it for
the required six-month interjurisdictional review. The plan was reviewed at the August 28, 2018
Planning & Zoning Commission, along with an open house and public hearing. It was subsequently
approved at the September 4, 2018 City Council meeting. This memo summarizes the responses
received during the comment period and from the Metropolitan Council’s informal review, including
potential changes to the draft plan. It also describes next steps for plan review and approval.
As required, the plan was circulated to adjacent jurisdictions for review and comment, from September
12, 2018 to March 12, 2019. The jurisdictions included:
• City of Edina
• City of Minnetonka
• City of St. Louis Park
• Hennepin County
• Hopkins School District #270
• Edina School District #273
• St. Louis Park School District #283
• Minnehaha Creek Watershed District
• Nine Mile Creek Watershed District
• Three Rivers Park District
• Minnesota Department of Natural Resources (MN DNR)
• Minnesota Department of Transportation (MnDOT)
Consistent with the City’s “Take it to them” public engagement strategy and the American Planning
Association’s Sustaining Place “Authentic Participation” process, the City took the extra step to put the
draft plan online and solicit public comments through social media. While the City only received 3
comments from this source, each of them offers a unique perspective the City might not have otherwise
heard. These comments are noted in the attached Comment Tracker as from Peg Keenan, ICA Food
Shelf Director, Nathan Miller, Resident and Anonymous Online Comment.
2
By the conclusion of the comment period, the City had received comments from the following
respondents. The additional stakeholders listed reflect the City of Hopkins’ commitment to higher
standards in priority areas, particularly related to equity, the environment, and housing affordability.
While this memo is focused on elements that need to be updated in the plan, the comments included
recognition that the city has already made significant progress on these issues.
• Minnehaha Creek Watershed District
• Nine Mile Creek Watershed District
• Three Rivers Park District
• Minnesota Department of Natural Resources (MN DNR)
• Minnesota Department of Transportation (MnDOT)
• Great Plains Institute
• Center for Economic Inclusion
• Larry Hiscock, Comprehensive Plan Steering Committee member and housing advocate
For the purposes of the review, it is not required that comments be received from all jurisdictions. While
the City did not receive any written comments from adjacent cities or the county, Hopkins staff have
met with the staff of St. Louis Park and Minnetonka to discuss shared issues and areas for collaboration.
Ongoing coordination between cities and other stakeholders ensures that there is a regular opportunity
to address and manage any concerns that arise.
During the six-month review, the plan was also submitted to the Metropolitan Council for informal
review. This optional step provides an opportunity for feedback regarding consistency with
Metropolitan Council standards in advance of the formal review. After the Metropolitan Council staff
provided comments, City of Hopkins staff sat down with them to talk through potential responses.
Summary of Comments Received
The comments received during the comment period and from the Metropolitan Council’s informal
review are included in the attached table. This also includes comments from the Planning Commission
and public hearing in August 2018, in the interest of completeness, although some have already been
addressed in the current draft. A summary of the comments by plan element is provided below.
The table distinguishes between Incomplete Comments and Advisory Comments. Incomplete Comments
are identified by the Metropolitan Council as incomplete or inconsistent with regional policy, and must
be addressed for the plan to be approved. Additionally, there are advisory comments that may still be
important, but are not necessary to meet regional policy standards.
• Introduction and Forecasts
o Need more details as to intentional inclusivity of engagement process
o Ensure table of contents is numbered
o Update population and employment forecasts to reflect fact that growth has exceeded
expectations in recent years
3
Built Environment
• Land Use
o Add more detail to housing density guidance around transit station areas to reflect
minimum density requirements of 50 units/acre, per Metropolitan Council guidance
o Various clarifications regarding wording and calculations related to density
requirements
• Transportation
o Add more information on roadway lanes
o Identify local issues related to freight traffic
o Update transit facility information with data on current facilities, existing bus service,
and planned improvements
• Housing
o Strengthen language and guidance for how affordable housing tools will be used in the
community
o Clarify approaches in housing implementation plan regarding specific tools
o Consider additional housing strategies such as accessory dwelling units, inclusionary
housing policy, and tenant protection policies
o Ensure policies reflect high percentage of renters in Hopkins
o Clarify language regarding encroachment into single family areas
Social Environment
• Quality of Life
o Address artist housing in context of broader affordability and equity needs
• Sense of Community
o Disaggregate data by race where possible to show disparities, and identify needs and
opportunities
o Add more tools and approaches for addressing racial equity
Natural Environment
• Sustainability and Natural Resources
o Update solar access section with performance standards if possible
o Add policies to support native plantings and landscaping
o Add policies that take planning for wildlife into consideration with development and
transportation projects
o Include additional natural resource information in the plan
o Add resilience policies related to electric vehicles, emergency response, and stormwater
management; lessen focus on wind power as its not applicable in Hopkins
o Consider targets for carbon reduction and other renewable energy targets
• Surface Water Management
o Extensive comments from both watersheds related to compliance, documentation, and
proper procedures – most of which can be fulfilled directly
o Request for citywide stormwater modeling may be accomplished over time, but does
not seem necessary at present
4
• Water Supply
o Review of water supply plan is occurring on a parallel path; revised version will be
incorporated here, reflecting MN DNR and Metropolitan Council input
• Wastewater
o Include documentation of existing system and its characteristics
o Need copies of intercommunity service agreement
o Additional detail as to approach to managing inflow and infiltration
• Parks and Trails
o Minor comments related to 17th Avenue study status and length of existing trails
Economic Environment
• Economic Competitiveness
o Focus on encouraging business start-ups by people of color, as well as targeting
education and other strategies to these populations to support equity
o Include reference to growing tax base and using resources efficiently
• Downtown
o Emphasize the uniqueness of downtown as a key differentiator, including central social
district concept
• Implementation
o Strengthen language in implementation steps around race equity, including tracking
disparities and other tools
o Strengthen policy language and toolkit for affordable housing and tenant rights
o Zoning and parking related priorities should be short term
Recommendation and Next Steps
At this time, it is requested that the Planning and Zoning Commission review the comments and draft
responses, and determine if there should be any changes to how comments are addressed.
When Planning and Zoning Commission and City Council reviews are complete (including a public
hearing), the plan will be approved by resolution for submittal to the Metropolitan Council for formal
review. Once the plan is submitted, the Metropolitan Council will have 15 business days to do a
completeness review. If any issues are found, they will be brought to the attention of the city via a
letter. The City then will have an opportunity to work with the Metropolitan Council to resolve any
remaining items before final approval by both bodies.
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City of Hopkins Comprehensive Plan Comment Tracker (Comments as of 3/12/19)
Comments from six-month interjurisdictional review, Metropolitan Council preliminary review, and 8/28/18 public hearing
Introduction
Advisory Comments
Number Comment From Proposed Response
1. Page 6 describes the public engagement tools and strategies that informed the
comprehensive plan. The Center supports the City for designing a process intended to
engage all segments of the community. In particular the “Take It To Them” meetings were
focused on reaching people who are usually underrepresented in public engagement
processes. The Center encourages the City to go beyond the descriptions of the strategies
and their intent by reporting --in the plan’s narrative» how effective these efforts were at
engaging all segments of the community. Appendix A2 notes that only 10% of respondents
to the Cultivate Hopkins survey were POC, while 27% of respondents to the Race & Equity
survey were non-white. In both cases, the participation falls short of the City’s 40% share of
People of Color. Also, what is the significance of the demographics of the survey samples
and the other engagement activities? How might it have affected the themes identified in
the plan?
The Center applauds the plan’s assertion (on page 9) that the City’s diversity “isn’t just a
change in composition — it’s driving growth.” This statement is followed by a discussion of
demographics, recognizing that population growth in Hopkins is driven by People of Color.
The Center urges the City to expand this discussion of growth beyond population to
economic growth: including everyone in the economy is the path to prosperity for all.
Center for
Economic
Inclusion
Add more insights from
community
engagement process to
narrative. Identify
current shortcomings
and clarify that the city
has a commitment to
ongoing progress in this
area.
2. Molly Van Avery is a friend/neighbor of mine – I love the poetry wagon! Great Plains
Institute
Comment
acknowledged
3. Include numbers in table of contents 8/28/18
Planning
Commission
public input
Numbers have been
added
2
4. Let’s keep calling out that this is the land of indigenous people. The phrasing at the top of
the plan can be read as if the treaties establishing US settlement were fair. In telling the
history we have got to call out the war on native Americans and the conquest of America.
Nathan
Miller,
online
comment
portal
Comment
acknowledged
Forecasts
Advisory Comments
Number Comment From Proposed Response
1. Council staff find that recent population and employment growth have significantly
exceeded what was expected in the current decade. Council staff recommends making the
following immediate adjustment to the population and employment forecasts, as follows:
Met Council Forecasts adjusted
throughout plan to be
consistent with
recommended values
BUILT ENVIRONMENT
Land Use
Incomplete Comments
Number Comment From Proposed Response
1. On pages 32 and 81-20, the Plan states that the 2040 Transportation Policy Plan
(TPP) recommends higher minimum residential densities of 50 units/acre in transit
station areas. This is incorrect. It is not a recommendation, but rather a minimum
requirement related to the regional transportation system for cities with the
community designation of Urban Center. The areas identified in the Plan for
redevelopment within the City’s three station areas are guided with ranges of 20—
Met Council Modify text to describe that
sites adjacent to station
platform areas are guided for
higher densities (50-120
units/acre) as opposed to the
periphery (25-50 u/a)
3
100 units/acre for the Downtown Hopkins station area (Downtown Center guiding
land use) and a range of 20—60 units/acre in the Shady Oak Road and Blake Road
station areas (Activity Center guiding land use).
On pages 32 and 81-20, the Plan suggests that the density range is lower and
broader than otherwise would be because of its application city-wide. The Plan also
states that there is an “expectation that densities like these are achievable and
encouraged on redevelopment parcels in the station area, and that the City will
work to support this.” However, figures in the Plan that identify redevelopment
areas and guiding land use (Figures 81.7, 81.8, 81.9, and B1 .11) indicate that most
of these areas fall within the 1/2 mile station area. Our records show that most
recent development in Hopkins’ station areas meet the minimum 50 units/acre; and
in some cases, recent projects likely exceed the maximum density of 100 units/acre,
such as the Gallery Flats project at 135 units/acre.
On pages 32 and 81-20, the Plan states that it will “work to support” higher density
development. While the City has clearly demonstrated this, such a statement is not
sufficient to ensure that sites near the region’s transit system are preserved by the
comprehensive plan for projects at densities that are consistent with the regional
investment, market context, and the minimum density required by the TPP.
Staff offer some suggestions for rectifying these inconsistencies. Please keep in
mind that the minimum density is an average of the minimum density of planned
land uses for areas guided for development and redevelopment. The City could
guide some locations at higher minimum densities (e.g., 75 units/acre) and some
with lower (e.g., 40 units/acre). Aside from creating a new land use category, the
Plan could differentiate among minimum densities based on location (eg, within 1/4
mile of the station or along certain corridors).
Advisory Comments
Number Comment From Proposed Response
1. On page B1-36, and in Table B1.13, the Plan describes zoning that is inconsistent
with the policies related to densities that are proposed in the Plan. The zoning
indicates that less dense development (as low as 10 units/acre in the Downtown
Center, Activity Center, and Neighborhood Center) is possible under these
Met Council Clarify that zoning will be
updated to match future land
use guidance after plan
completion
4
regulations, but that higher densities “could be approved” through the City’s
planned unit development and conditional use permit processes. This contradicts
the policy intent of the guiding land use, creates an inconsistency between the
comprehensive plan and official controls, and appears to contradict the
Recommendations section on page F1-5, which relates to implementation of zoning
changes.
2. Based on recent housing market analysis for the three transit station areas, the Plan
suggests (Page B1-4) that a forecast increase may be warranted through a
comprehensive plan amendment. We encourage the City to propose a forecast
adjustment now as part of the formal Plan submittal, and to consult staff before
doing so. The 2014 Marquette Advisor’s study that the Plan cites suggests a market-
driven capacity of 2,424 units for the three station areas combined. This is much
higher than the forecasted growth, which can be accommodated by the Plan at
minimum guided densities (notwithstanding the inconsistency of guiding densities
being lower than minimum requirements of the TPP).
Met Council Incorporate forecast
adjustment in the plan as
recommended
3. On page B1-40, the Plan states that the aspiration for density in station areas is
“closer to 75-100 units per acre.” This statement conforms to and supports land use
policy in the TPP, but it does not align with the guiding densities in two of the
station areas (Activity Center 20—60du/acre.)
Met Council Modify text to clarify that areas
closer to station will be guided
for higher densities
4. On page B1-40, Table B1.17 identifies incorrect time ranges. Presumably, the
timeframes should be 2015-2020, 2021—2030, and 2031-2040. Please clarify and
note related comments under Housing.
Met Council Make corrections to time
ranges where appropriate
5. On page 28, include reference to the fact that the land use approach is different
than in other communities, and add percentages of land use acreages.
8/28/18
Planning
Commission
public input
Make changes as suggested
6. On page 31, du/ac should be spelled out “dwelling units per acre” 8/28/18
Planning
Commission
public input
Make change as suggested
7. On page 36, clarify policy on preserving and enhancing existing housing units to
make it clear it is not intended to imply direct subsidy
8/28/18
Planning
Commission
public input
Make change as suggested
5
8. I work for Cargill at Excelsior Crossings and live in The Moline. Graduated college in
2015 with a Business & Technology degree. I’m from Wichita, Kansas originally.
High-level thoughts: I love increasing density and diversity. I wish my home town
planned like this. This makes me want to invest in Hopkins.
General rule: Kill the golf courses! Kill the parking lots! Love seeings this as a
transformational plan in terms of zoning Side note: I want to see rooftop patios and
incredible green spaces. For inspiration of making the arts community work with
small businesses: See Douglas Design District in Wichita How do we attract a
Spyhouse coffee location to Hopkins? I think that we have to consider many of the
ways this plan could fail. How do we prevent implementation of the plan under
delivering? How do we protect from Developers taking advantage of Hopkins? How
do we ensure ethics and accountability?
Nathan
Miller, online
comment
portal
Comment acknowledged
Transportation
Incomplete Comments
Number Comment From Proposed Response
1. Identify the future number of lanes for principal and A—minor arterial roadways. Met Council Provide information as
requested
2. Map current heavy commercial traffic volumes on principal and A-minor arterials. Met Council Volumes are already shown on
Figure B2-11
3. Identify any local roadway issues or problem areas for goods movement, such as
weight—restricted roads or bridges, bridges with insufficient height or width
clearances, locations with unprotected road crossings of active rail lines, or
intersections with inadequate turning radii.
Met Council Provide information as
requested
Advisory Comments
6
Number Comment From Proposed Response
1. Page 197, paragraph 3, consider the following replacement language
The station area includes the platform, passenger drop-off, and a large surface
park-and-ride facility with parking options north and south of the station platform
with up to1070 stalls. In coordination with the Shady Oak Station Area
Development Strategy, the parking lot north of the station has been designed to
accommodate future development and a potential future parking structure.
Met Council Update language as suggested
2. Page 201 of pdf, paragraph 1, make the following correction:
“Figure 81.8 shows the location of the Blake Road Downtown Hopkins LRT station.”
Met Council Make correction
3. Page 204, make the following correction:
The station area, located along the south side of the Cedar Lake LRT Regional Trail,
includes the platform, bus stop, an 89-stall park-and-ride lot...
Met Council Make correction
4. Page 234 / Appendix 82, Blake Road Station, make the following correction:
The SWLRT project includes an 89-stall park and ride lot.
Met Council Make correction
5. Page 234 / Appendix 82, Shady Oak Station, consider the following language:
A large surface park-and-ride facility with parking options north and south of the
station platform with up to 1,070 stalls is planned for opening clay. In coordination
with the Shady Oak Station Area Development Strategy, the parking lot north of the
station has been designed to accommodate future development and a potential
future parking structure. A Wayfinding will guide users to the variety of uses in the
station area.
Met Council Add language; need to clarify
“Wayfinding” suggestion
6. Page 266, the Bus Route 12 paragraph, add the following:
Bus Route 12 is a regular local route operated by Metro Transit. It travels between
Minnetonka, Hopkins, St. Louis Park, and Minneapolis. In Hopkins, it travels mainly
along Excelsior Boulevard, Mainstreet, and 11th Avenue south of Mainstreet. This
route runs on weekdays primarily during peak hours.
Met Council Update language as suggested
7. Page 266 the Bus Route 612 paragraph make the following changes.
This route runs on weekdays off-peak and, primarily during peak hours, with more
limited hours on weekends and holidays
Met Council Update language as suggested
8. Page 266, the Bus Route 615 paragraph make the following change:
Bus Route 615 is a regular local route operated by Metro Transit.
Met Council Update language as suggested
9. Page 266, add a paragraph for Bus Route 667 as follows:
Bus Route 667 is an express bus route operated by Metro Transit. The route runs
east/west connecting Minnetonka, Hopkins, St. Louis Park, and Minneapolis. ln
Met Council Update language as suggested
7
Hopkins, it travels on CSAH 7. This route runs eastbound in morning peak hours and
westbound in afternoon peak hours on weekdays.
10. Page 266, the Bus Route 670 paragraph, make the following changes:
Bus Route 670 is an express bus route operated by Metro Transit. The route runs
east/west connecting Excelsior, Minnetonka, Hopkins, St Louis Park, and
Minneapolis. ln Hopkins, it travels primarily on CSAH 7, Excelsior Boulevard and
Mainstreet.
Met Council Update language as suggested
11. Page 266, add a paragraph for Bus Route 671 as follows:
Bus Route 671 is an express bus route. The route runs east/west connecting Orono,
Excelsior, Minnetonka, Hopkins and Minneapolis. ln Hopkins, it travels on
Minnetonka Boulevard. This route runs eastbound in morning peak hours and
westbound in afternoon peak hours on weekdays.
Met Council Update language as suggested
12. Page 266 under Transit Facilities
The park-ride at 10201 Excelsior Boulevard is a 52 vehicle lot, not 300.
Met Council Make correction
13. On page 45, add transit policy language that supports the development of a bus
circulator between LRT stations and Downtown; also clarify the definition of
demand responsive transit and include examples
8/28/18
Planning
Commission
public input
Make changes as suggested
14. I love the shift to complete communities and getting rid of the automobile. How do
we move Hopkins towards being a dutch-style car-free community?
https://www.forbes.com/sites/carltonreid/2019/02/21/wealth-guru-plans-dutch-
style-car-free-bicycle-friendly-city-near-boulder-colorado/#54488e9ed91d
Could we get sponsorship and support from organizations exploring new urban
design in America? Are there streets where we would entirely remove automobiles
and just turn in to walkways enabling entirely new development and use? Trees,
green spaces, pop-up shops, parkways.
Happy to see ridesharing design called out. More bike lanes! Make sure the
shopping and attractions are bike friendly - pull people in to Hopkins on their bikes.
Trailheads concept - how can we make the whole town of Hopkins a trailhead. Bike
shops, gear outfitters, art, coffee, beer, healthy food. Hopkins is here to encourage
you to bike from your downtown apartment to lake Wayzata. Or from your
suburban home into the city. As we look at transit - could we make it simpler and
Online
comment
portal
Comment acknowledged
8
ask: How could this plan help to encourage more people o ride the bus? For buses -
where do people who live in Hopkins work?
Housing
Incomplete Comments
Number Comment From Proposed Response
1. As described in under the Land Use comments above, there are inconsistencies
between the minimum densities described in zoning (Table 81.13) and other
elements of the Plan, which describe a higher minimum density.
Met Council Clarify that existing zoning will
be modified as part of plan
implementation
2. in Table B1.17, decades overlap by using rounded years (e.g., 2020-2030 and 2030-
2040). Please differentiate the decades as 2021-2030 and 2031-2040.
Met Council Make change to date ranges as
requested
3. The City’s allocation of affordable housing need is forecasted for the 2021-2030
decade. The Plan needs to identify how many high density units are possible in that
exact time range.
Met Council Add clarifying language
regarding unit counts
3. On page B3-20, Table B3.9 includes numerical recommendations for new rental
housing by affordability for each LRT station area (from the “SWLRT Housing
Study”). The preceding text states that the LRT station areas can “accommodate a
significant amount of affordable units...” While this possibility exists, the Council
does not consider a “recommendation” by station area to meet the need. The
Council evaluates the accommodation of affordable housing need by the amount of
land the Plan guides for development or redevelopment at minimum densities.
Council staff recommend a modified version of Table B1.17 that includes the 2021-
2030 decade.
Met Council These are just results from a
study, not a response to the
affordable housing allocation.
Adding language to clarify this.
4. The Housing Implementation Plan on pages 20-22 of Appendix B3 does not include
circumstances and sequence in which tools would be used. The narrative that
precedes the table refers to a range of approaches by which the City can meet the
goals. However the Plan needs to include a description of what roles the City can
play (eg, apply, promote, refer, administer, fund) and under what circumstances the
City would consider doing so (eg, near transit, serving large families, etc). An
example is shown in the Local Planning Handbook -
Met Council Add more detail regarding
roles, circumstances, and
sequences for housing
implementation
9
5. On page 16 of Appendix B3, the Plan states on “a case-by-case basis, Hopkins will
consider financial participation in housing redevelopment projects when projects
provide demonstrable public benefits consistent with this Comprehensive Plan and
City redevelopment policies.” The purpose of the implementation plan is to lay out
what types of projects the City would prioritize when considering those tools so
that community members and developers know what projects to explore in the
City.
Met Council Add language regarding what
criteria the city uses to
determine appropriate
financial participation in
redevelopment projects
6. Housing tools that are mentioned, but are not paired with a description of
circumstance and situation of use include:
• Tax Abatement (include circumstances of use and AMl)
• Tax increment financing (include circumstances of use and AMI)
• Opportunities for partnership with Hennepin County to use HOME or CDBG
funds (include circumstances of use and AMI)
• Livable Community Act programs (include circumstances of use and AMI)
• Site Assembly, including partnership with Land Bank Twin Cities (include
when site assembly might be used, AMl of developments that site assembly
is preferred to support, and when partnership with Land Bank Twin Cities
would be considered)
• Date/sequence of zoning and subdivision ordinance adoption (e.g., 2020 or
within 2 years after comprehensive plan adoption)
• Preservation strategies, like community land trusts, low-interest rehab
programs, and tools that preserve private unsubsidized housing (4d)
(include circumstances of use and AMI)
Met Council Add more detail regarding
circumstances and situation of
use for each tool
7. Implementation Plan
Table 83.11 successfully links tools to needs, but does not consistently link to
household AMI/levels of affordability or mention all widely accepted tools, which
are required to be considered consistent. These include:
• Tax abatement
• TIF
• First-time homebuyer programs
• Livable Community Act programs
• Site Assembly
• Community land trusts
• Low-interest rehab programs
Met Council Add detail on applicable levels
of affordability in relation to
housing tools
10
8. To be consistent, all widely used tools must be acknowledged. Some widely used
tools to address housing needs aren’t included:
• Support for or application of various funding sources within Minnesota
Housing’s Consolidated RFP
• Partnership with Hennepin County to use Affordable Housing Incentive
Fund (AHIF)
• Housing Bond Issuance
• https://metrocouncil.org/Handbook/Fi/es/Resources/Fact-
Sheet/HOUSING/Municipal-Bond-Issuance.aspx
• Partnership, possibly with Land Bank Twin Cities for site assembly and
vacant and abandoned property control through First Look.
https://metrocouncil.org/Handbook/Files/Resources/Fact-
Sheet/HOUSING/Site-Assembly.aspx
• Participation in housing-related organizations, partnerships, and initiatives
https://metrocouncil/.org/Handbook/Files/Resources/Fact-
Sheet/HOUSING/Collaborating-on-Housing-Strategies.aspx
• Encourage or advocate for the creation of a community land trust to
increase affordable homeownership option
• Preservation tools, including monitoring expiration of LIHTC properties, and
preserving public housing.
• A local Fair Housing policy (more info provided below)
• All widely used tools are included in Housing Tools
https://metrocouncil.org/Handbook/Files/Resources/Fact-
Sheet/HOUSING/Recognized-Tools-and-Resources. aspx
Met Council Add details on all widely used
housing tools
9. All housing tools described should be linked clearly and consistently to stated
housing needs. An example is shown in the Local Planning Handbook
https://metrocouncil/org/Handbook/Files/Resources/Fact-Sheet/HOUSING/Linking-
Tools-to-Needs.aspx
Met Council Add detail linking housing tools
to stated housing needs
Advisory Comments
Number Comment From Proposed Response
1. This Plan would be stronger if there was a clearer connection between data and
policies. Staff appreciates a Plan where the main body is very readable and
supplemented by data in the appendices. However, there are very few connections
between the appendix and the policies in the body of the Plan. For instance, how
Met Council Add references between main
plan and appendices
11
does the information about housing and transportation costs inform Hopkins’
policy? Staff suggests referring to the housing implementation appendix in
the housing chapter.
2. With respect to a Fair Housing policy, local housing policies do not mean that cities
should or can manage or administer Fair Housing complaints. A local fair housing
policy rather ensures the City is aware of fair housing requirements with regard to
housing decisions and provides sufficient resources to educate and refer residents
who feel their fair housing rights have been violated. This can be as simple as having
links to resources on the City’s website. The Metropolitan Council will require a
local Fair Housing policy as a requirement to draw upon Livable Communities Act
(LCA) awards beginning in 2019. To learn more, and review a template local fair
housing policy, please refer to the following resources:
Creating a Local Fair Housing Policy webinar
https://www.youtube.com/watch?v=38JY4pNGnZ8&feature=youtu.be
Best Practices
https://metrocouncil.org/Handbook/PlanIt/Files/Webinar-Fair-Housing-
Handout2.aspx
Policy Template (Click on Handout 1 under the implementing A Local Fair Housing
Policy at the bottom of the screen)
https://metrocouncil.org/Handbook/Training/Webinars.aspx
Met Council Clarify City’s intention and
policy direction on fair housing
3. Council staff encourages the City to consider an Accessory Dwelling Unit (ADU)
policy or allow them as a permitted use. This is a unique way to diversify housing
choices within existing single-family neighborhoods.
Met Council Include language that says the
city will evaluate the potential
to incorporate ADUs
4. Council staff encourages the City to consider a formal Inclusionary Housing policy,
which have recently been adopted in Brooklyn Park, Golden Valley, and Richfield.
Met Council Include language that the city
will evaluate the potential to
adopt a formal inclusionary
zoning policy
5. Council staff encourages the City to consider tenant protection policies to support
efforts to preserve naturally occurring affordable housing.
Met Council Add language regarding city’s
ongoing work on developing
tenant protection policies
6. All of the existing housing data (including the map of ownership units above and
below the price affordable to households earning 80% AMI) sourced from the
Metropolitan Council have been updated with 2016 data. Consider reviewing the
Met Council Make any updates needed with
current data as appropriate
12
updated Existing Housing Assessment on Hopkins’ community page in the Local
Planning Handbook and updating any relevant data.
htfps://metrocouncil.org/Handbook/FiIes/Existing-Housing-Assessment/02394417
Hopkins ExistingHsg.aspx
7. On page 4 of Appendix B3, text refers to “the table above,” but there is no table
above that text.
Met Council Make correction
8. On page 19 of Appendix B3, because the Plan defines household income at AMI
with descriptions on page 19, these terms can be used in the Implementation Plan
to be consistent,
Met Council Make suggested language
change
9. On page 19 of Appendix BS, text refers to the allocation of affordable housing need
as a goal. The allocation is a forecast of actual households expected to come to the
region at various income levels. Cities must plan for that allocation per the
Metropolitan Land Planning Act, but are not responsible for creating those units.
Since the Council negotiates affordable housing goals with cities that participate in
Livable Communities Act programs, we prefer that the allocation of need not be
referred to as a goal, which can confuse the different purposes of the two
measures.
Met Council Make suggested language
changes
10. Council staff recommend generalizing the columns in Table 83.11 (implementation
Opportunity, Policy and Fiscal) into a single “Tools” category. Since the table needs
more detail as to how and when the City might use these tools, further
differentiating the type of tool is not necessarily helpful and can make the
information seem more complicated than it needs to be.
Met Council Make suggested formatting
changes
11. The City of Hopkins 2040 Comprehensive provides a solid framework to guide the
community for years come. The community is strong, diverse and ripe for
investment because of the local economy, sound decisions made by local leaders
and the approved METRO Green Line Extension. At the same time, Hopkins
experiences many of the same racial and economic disparities as the rest of the
region. The disparities in our region are not by accident. They are the result of
deliberate actions by policy-makers, private citizens and business leaders. Two
examples are the use of racial housing covenants and redlining used to preserve
and build white wealth while denying opportunity and disinvesting in communities
of color.
Larry Hiscock Comment acknowledged. More
detailed response to
subsequent comments.
13
It is vital that the City of Hopkin’s 2040 Comprehensive Plan incorporates stronger
language related to racial equity, and include explicit actions and indicators to
ensure Hopkins is an inclusive community in the future.
Bold Action Required
City of Hopkins is at 100% risk of gentrifying according to a 2019 study published by
the Center for Urban and Regional (CURA) at the University of Minnesota. In the
study all three census tracks were considered vulnerable in 2000. Since 2000, the
census track for downtown Hopkins has already begun the process of gentrification.
The other two vulnerable census tracks are at greater risk of gentrification “given
the demonstrated impact of transit investment on gentrification, the rate of
conversion of vulnerable neighborhoods into gentrified neighborhoods may
accelerate in the future (Goets and Damiano, 2019).”
It is vital that the stronger policy language be included in the Comprehensive Plan
to provide latitude for the City Council and City Staff to approve ordinances,
policies, and development agreements that will preserve existing naturally
occurring affordable housing units, require long-term affordable housing units in
new construction, protect the rights of renters and mitigate the harm to people
renting caused by displacement.
12. On page 55, clarify that enforcing housing and yard maintenance is not intended to
represent a change in practice that is more proactive than the current system; also
clarify what it means to protect single family neighborhoods from “encroachment”
– ensure that new description references specifically development
8/28/18
Planning
Commission
public input
Make clarifications and provide
descriptions as suggested
13. There is an intersection between affordability in Hopkins and keeping older
buildings up to date. Renovated properties may increase in value/rent, making
them less affordable. Plan should acknowledge the challenge in balancing these
priorities.
8/28/18
Planning
Commission
public input
Ensure that the plan reflects
the need to balance priorities
14. The plan addresses both ownership and rental housing. From experience with the
community, it seems that renters are typically here because they are committed to
this community and want to stay here. Some have rented in the area for many
years.
8/28/18
Planning
Commission
public input
Comment acknowledged
15. The region has entrenched racial and economic disparities, which reflect past
actions by cities – which in turn have a responsibility to address them
8/28/18
Planning
Ensure plan reflects a range of
housing tools to benefit renters
14
The comprehensive plan generally reflects values around equity and disparities,
though it may need stronger language in terms of policies and more clarification as
to roles and responsibilities. Policies should reflect that 66% of housing is currently
rental, so rental-related policies benefit the majority of the community. Need more
clarification in terms of new public sources for preserving existing housing stock and
policies for new housing such as inclusionary zoning and right of first refusal. (note:
individual indicated afterwards that more specific comments to this effect will be
forwarded to the City during the comment period – these comments are included
here as well)
Commission
public input
16. Thanks for this opportunity. As a member of the Blake Road Corridor Collaborative
and the director of a local non-profit (ICA Food Shelf) I am pleased with the overall
Comprehensive Plan. This is hard work and I commend all the community members,
city council and city staff on the work that went into this. Thank you. As housing is
part of this plan (Section 4), and especially as it relates to Hopkins large number of
naturally occurring affordable housing units, the fact that the SWLRT will be coming
through is a huge factor in the housing of Hopkins. In section 4 there is mention of
"Continue to explore public policy that provides protection against tenant
displacement.". It really sounds like a "plan to plan" which typically is something to
steer clear of in strategic planning (or in this case Comprehensive Planning). There is
no mention of tracking this or a goal knowing if this has been done. How will you
know how many people have been displaced but found other housing in Hopkins?
How will you know if people had to move to other communities? How will you
know if those displaced are our low-income residents? What indicator will be used -
a policy was created or not? Or a policy was created and this is the number/% of
residents displaced. A starting point might be to change "Continue to explore public
policy that provides protection against tenant displacement." to "Create a public
policy that provides protection against tenant displacement." and then a
corresponding indicator that tracks displacement. Not easy, but in my opinion the
item has no depth without some actionable item.
Peg Keenan,
online
comment
portal
At this time, the City is
considering a tenant protection
policy. The specific policy will
help determine the appropriate
indicators to track.
17. Thank you for the work on this plan. Here are a few thoughts: The narrative section
of the update to the plan notes the potential for displacement and gentrification to
occur in the city, and the importance of steps to prevent this. For example, in
Section 4 Housing, a policy listed under Goal 2 (on page 53) is to "Continue to
Anonymous
Online
comment
portal
At this time, the City is
considering a tenant protection
policy. The specific policy will
15
explore public policy that provides protection against tenant displacement." Could
this be carried through and reflected in the implementation section of the plan as
well? To this end, add an action step reflecting the desire to protect against
displacement and gentrification, and create a way to track whether (and to what
extent) displacement is occurring in the city in order to have a corresponding
indicator.
help determine the appropriate
indicators to track.
18. How we will we make the townhome south of Excelsior boulevard into a complete
neighborhood that meets the aesthetic standards laid out in the plan? Should there
be more in this plan that encourages development of additional units on single
family lots? See the Minneapolis Plan - building and renting back house and
additional units is an affordable wealth building strategy and enables senior living
and affordable housing options.
Nathan
Miller, online
comment
portal
Comment acknowledged
SOCIAL ENVIRONMENT
Quality of Life
Advisory Comments
Number Comment From Proposed Response
1. On page 69, do not specifically call out affordable housing for artists; artist housing
is not consistent with racial equity goals due to typical tenant mix; if it is included
emphasize the need for diverse residents; in general, focus should be on affordable
housing for everyone; counterpoint: artists bring vibrancy and unique perspectives
that add value to the community and so should still encourage artists to live here
8/28/18
Planning
Commission
public input
Update policy to include focus
on encouraging diversity in
artist housing, with a goal of
affordable options for all
2. 55% of ICA Food Shelf participants come from Hopkins. ICA also serves multiple
communities between Hopkins and Shorewood. This means that around 17.8% of
Hopkins residents at least occasionally use the food shelf – though not all are
regulars.
8/28/18
Planning
Commission
public input
Acknowledge the need for food
security and assistance in
narrative.
3. As we discuss Equity and Incusion: Can we promote new means of ownership?
Community financed and owned projects? How do we enable the diverse citizens
we bring in to invest in and become wealthy in Hopkins? I want more co-op
community owned apartments. I want more co-op employee owned businesses.
This plan will make developers rich. How could it grow the stable wealth of our
diverse citizens?
Nathan
Miller, online
comment
portal
Comment acknowledged
16
How could we learn how to organize civic life from new residents? Lets learn from
citizens who were born or educated elsewhere how they would provide city
services, lay out the physical environment, or ensure accountability. We need to
build a new Hopkins community of everyone who has found their way to living here.
We need to define new ways to celebrate together, mourn together, and progress
towards a shared vision of the future. What holidays do we need to add to the
public calendar to celebrate with our whole community? How could mainstream
Hopkins reflect all of these? Could the city of Hopkins be a pioneer in community
policing? Radically change the role of police in the community. Hold the police
accountable to community boards. Educate police officers as social workers and
treat community health issues as health issues that we can help heal. Do we need to
pay our police officers more and then hold them to higher standards and expect
more education, community engagement, and working together to make a stronger
community?
Sense of Community
Advisory Comments
Number Comment From Proposed Response
1. The Center applauds the City for incorporating racial equity and economic inclusion
into several of the plan’s foundational statements, including:
1. “Race and Equity” was identified through the planning process as one of the eight
focus areas (priorities for policy and plan implementation): “Proactively identify and
address racial disparities in the community and promote equity for everyone.”
2. The Cultivate Hopkins vision statement includes “equity” as one of the three
guiding principles (together with sustainability and resilience).
3. The Economic Competitiveness section provides “direction for a healthy, robust
and equitable economy,” including a goal to “promote economic equity in Hopkins,
to benefit residents regardless of identity or background.”
4. The Sense of Community section provides “direction for community connections,
equity and inclusiveness, and culture and identity,” including a goal to “proactively
Center for
Economic
Inclusion
Comment acknowledged
17
support the development and maintenance of an equitable and inclusive
community.”
Equity and accessibility are also addressed in a goal within “Parks and Trails.”
Additionally, a theme of openness to change pervades the plan, which can support
the achievement of racial equity goals.
2. The Center supports the data disaggregation by race in many of the plan’s
appendices. Examples include: poverty, unemployment, labor force participation,
household income, health insurance and homeownership. Similarly, the Race and
Equity Survey data are disaggregated by race, illuminating differences in the lived
experience among whites and People of Color. The Center encourages this type of
data analysis because it enables the City to identify where racial disparities exist, a
necessary step towards closing them. Opportunities exist to disaggregate other data
in the plan by race; one example is housing cost burden. Also, by disaggregating the
Cultivate Hopkins Survey data and Online Issues Mapping by race, the City could
identify any specific needs and opportunities expressed by People of Color. The City
might also consider including data on vehicle-free households in the plan and
disaggregating it by race. The plan’s appendices include spatial analyses such as a
dot map showing the residences of People of Color, and a map of the City’s Area of
Concentrated Poverty. Also included is a map that shows job access (low-wage jobs
and low-wage workers in 2010) and a map of regional transit accessibility. The
Center supports these spatial analyses by race and income and encourages the City
to replicate this approach on a local basis. For example, the City could map People
of Color and the ACP in relation to community assets, investments and challenges.
This would enable the City to identify opportunities to advance equity and evaluate
past efforts.
Center for
Economic
Inclusion
Disaggregation of data was
done where possible. In some
cases, the data sets were too
small to make meaningful
distinctions by race and
geography, or data were not
complete enough.
Added implementation step
regarding spatial analysis
recommendation and other
analysis.
3. The plan contains several policies and action steps to promote racial equity and
economic inclusion, most notably within the Sense of Community, Economic
Competitiveness and Implementation sections. The Center supports these policies
and strategies and offers suggestions to strengthen them in the “Additional
Comments” section below. In general, the Center encourages more specificity in
language, leveraging existing resources for more efficient implementation, and an
asset—based approach to economic inclusion.
Center for
Economic
Inclusion
Comment acknowledged
18
4. Several parts of the plan state the City’s intent to evaluate the impact of policies
and strategies on People of Color in Hopkins. For example, Goal 2 under Sense of
Community contains a policy about using a racial equity toolkit, and the
Implementation section includes an action step to “assess equity impact of specific
City policies and regulations.” The Center supports these evaluation plans and
encourages the City to feature them more prominently in the plan. One way to do
this would be to add an additional section in the “Implementation Tools” section
under the “Public Program and Tools” with the subtitle “Racial Equity Evaluation.”
This section could describe in detail how a racial equity tool will be applied to
decisions and investments within the City. By doing so, the City would demonstrate
that racial equity evaluation is a high priority and that it will apply across everything
the City does, not only in the predictable areas such as workforce diversity.
Racial equity evaluation works best when a diverse set of stakeholders provide
input into criteria and goals. These processes can provide learning opportunities for
community members, staff members and others. Therefore, the Center encourages
the City to commit resources to form strong, collaborative partnerships with the
community and regional partners to ensure the most effective evaluation of its
investments.
Center for
Economic
Inclusion
Added implementation step
regarding investigating
potential to use a racial equity
toolkit.
5. Goal 2 under “Sense of Community” outlines four policies intended to “proactively
support the development and maintenance of an equitable and inclusive
community.”
The first policy under this goal is “celebrate, respect, and represent the diverse
social and cultural backgrounds of the community and its members and seek to
address any disparities in outcomes.” Recognizing that this policy contains a
multiplicity of related but distinct actions, the Center suggests that the City break
this policy into two: one policy focused on process (celebrate, respect and
represent) and the other focused on outcomes (address disparities in outcomes).
Also, the Center suggests that the outcomes-focused policy should refer to the
racial disparities that the plan has already uncovered and describe how it will
address them. For example, a revised outcomes-based policy could read: “close
racial disparities in outcomes [link to appendix] through dedicated resources,
partnership, ongoing evaluation and continuous improvement.”
The second policy under this goal is “explore the development of a race and equity
toolkit to evaluate public and private projects.” Rather than developing a new
Center for
Economic
Inclusion
Clarify and strengthen language
of policies as recommended.
19
toolkit, the Center encourages the City to move more quickly by leveraging one or
more of the many existing high-quality tools, such as GARE’s Racial Equity Toolkit
and the Equitable Development Principles and Scorecard. Also, the Center
encourages the City to apply the tool to ongoing programs and investments as well
as discrete projects. Finally, these tools are most effective when used by a group
with diverse perspectives, that includes staff, residents and other partners. A
revised policy might read: “systematically and collaboratively apply a racial equity
tool to public and private investments at multiple decision points, transparently
report the results, and make adjustments accordingly."
6. Second, in the Quality of Life Goal # 6, it uses the phrase "residents as empowered
partners". I love that phrase!!! While this was used while talking about
crime/safety, it would be great to use that phrase in other community engagement
areas that occur in the Sense of Community Goal 1 area. And of course ensuring
residents are empowered partners is not an easy thing to do, I think you can see it
done in the Blake Road Corridor Collaborative work. It can be done. It has been
done in Hopkins. But even in this feedback form, have you made this easy for all
residents to respond to? You may have and congratulations if you have been able to
ensure a diverse group could respond. Like senior residents without computers or
technology expertise, or those whose primary language is not English, but have
lived in this community for years or decades and are part of the amazing quilted
fabric that makes Hopkins what it is. I did not see where if this form was able to be
online in the other major languages used by Hopkins residents. Was the plan
translated into different languages. So even now you may not be getting the
feedback from the plan you need. With adding "residents as empowered partners"
to this part of the plan, it means not only gathering the ideas and empowering of
some of the community, but all segments of the community. Then, not only getting
ideas, but using them! It is so easy for those in positions of power to say, "oh, but
that won't work because..." How do those of us in power move outside our boxes
and utilize the collective wisdom of all our residents? Then not only using ideas
from different parts of the community, but having an indicator in this area - ex.
outcomes, processes, programs, plans, projects, etc. that reflect the needs and
interests of all residents. Thank you for this opportunity to respond.
Peg Keenan,
online
comment
portal
The plan documents a range of
community engagement
opportunities that were
provided throughout the
planning process in addition to
the online comment portal.
7. In the implementation section of the plan, Quality of Life Goal #6 describes
collaborating with "residents as empowered partners" to prevent and reduce crime
Anonymous
Online
Add reference to residents as
empowered partners to Sense
20
and increase perceptions of safety (page 122). I would suggest adding this
description of collaborating with "residents as empowered partners" to other areas
of the implementation section as well - particularly the areas that discuss
community engagement. One example would be Sense of Community Goal 1 -
expand the idea of "everyone participating" as currently stated in this goal to
include collaborating with "residents as empowered partners." In turn, in addition
to "level of involvement in community events and programs", add a potential
indicator to include "outcomes, processes, programs, plans, projects, etc. that
reflect the needs and interests of all residents."
comment
portal
of Community Goal 1, and
amend potential indicators as
noted.
NATURAL ENVIRONMENT
Sustainability and Natural Resources
Advisory Comments
Number Comment From Proposed Response
1. Overall, the resilience and solar access protection and development components
are quite impressive. Staff recommend including policies that quantitatively link
solar energy protection and development with greenhouse gas emissions. The
following policies from the City of Farmington’s draft 2040 plan may be helpful:
• Policy 4.1: Follow the state energy goal guidelines of reducing greenhouse
gas emissions to 20% of the City’s 2015 baseline levels by the year 2050.
• Policy 4.2: Establish interim goals every 5 to 10 years.
Met Council Acknowledge comment and
clarify plans to develop more
specific metrics already
addressed in implementation
plan.
2. Land Use. We encourage you to discuss the importance of enhancing access to
nature for your city’s residents. As the city intensifies development, the quality of
public and private green spaces becomes especially important. We recommend
including policies that encourage private and public developments to be planted
with native flowers, grasses, shrubs and tree species. Species such as monarchs rely
on these plants, and it does not take many plants to attract butterflies, other
beneficial pollinators as well as migrating and resident birds. Adding more native
plants into landscaping, not only enhances the health and diversity of pollinators
and wildlife populations, these plants can also help filter and store storm water, a
DNR Add reference to encouraging
use of native plants in public
and private development
21
policy that is consistent with other goals in your plan. For more information consult
DNR’s pollinator page.
Plant lists and suggestions for native plants can be incorporated into:
• Landscape guidelines to improve the aesthetics in for commercial and
industrial areas
• Street tree planting plans
• City gateway features
• Along ponds and waterways.
• Small nature play areas in children’s parks
• Along the edges of ballfield complexes.
• o Riparian areas
3. Development / Transportation Policies to Protect wildlife. Consider adding policies
that take wildlife into consideration as transportation and redevelopment projects
occur on private as well as public lands. To enhance the health and diversity of
wildlife populations, encourage developers of lands to retain natural areas or
restore them with native species after construction. One larger area is better than
several small “islands” or patches; and connectivity of habitat is important. Animals
such as frogs and turtles need to travel between wetlands and uplands throughout
their life cycle. Consult DNR’s Best Practices for protection of species and Roadways
and Turtles Flyer for self-mitigating measures to incorporate into design and
construction plans. Examples of more specific measures include:
• Preventing entrapment and death of small animals especially reptiles and
amphibians, by specifying biodegradable erosion control netting (‘bio-
netting’ or ‘natural netting’ types (category 3N or 4N)), and specifically not
allow plastic mesh netting. (p. 25)
• Providing wider culverts or other passageways under paths, driveways and
roads while still considering impacts to the floodplain.
• Including a passage bench under bridge water crossings. (p. 17) because
typical bridge riprap can be a barrier to animal movement along
streambanks.
• Use curb and storm water inlet designs that don’t inadvertently direct small
mammals and reptiles into the storm sewer. (p. 24). Installing
“surmountable curbs” (Type D or S curbs) allows animals (e.g., turtles) to
DNR Add policy regarding
considering wildlife in
transportation and
development projects.
22
climb over and exit roadways. Traditional curbs/gutters tend to trap animals
on the roadway. Another option is to install/create curb breaks every, say,
100 feet (especially important near wetlands).
• Using smart salting practices to reduce impacts to downstream aquatic
species.
• Fencing could be installed near wetlands to help keep turtles off the road
(fences that have a j -hook at each end are more effective than those that
don’t).
4. Open Spaces and Natural Resources. A map of the city’s natural resources would
help illustrate the concept that cities with significant urban development also
contain natural resources – some of which may not be as visible. Such a map could
include and label Minnehaha and Nine Mile Creeks, watershed boundaries,
remaining wetlands and could also show tree canopy density using a data source
such as the National Land Cover Database. The DNR’s data layer Pollution Sensitivity
of Near-Surface Materials on the MN Geospatial Commons would show the areas in
Hopkins with high sensitivity (a large band in the middle of the city).
DNR Many of these features are
mapped in the Natural
Environment element,
particularly the local water
management plan. Add map of
Pollution Sensitivity of Near-
Surface Materials.
5. Personal Autonomous Vehicles have the potential to increase emissions, where
shared vehicles would result in few emissions. I think it is important to connect this
back to climate and ensure the city (and other cities) doesn’t enable unintended
consequences w/ AVs.
• EVs & EV infrastructure are not mentioned until much later and only very
briefly – they would fit in here; I don’t see any implementation strategies
related either
Great Plains
Institute
Add implementation strategy
regarding encouraging use of
EVs in the city.
6. Consider adding resilience policies to Emergency Response: micro-grid, back-up
power to critical infrastructure, etc. This could fit better under hazard management
and mitigation
Great Plains
Institute
Add policy to emergency
response section regarding
resilience.
7. Add stormwater management, vegetation to Greener Development – addressed
nicely in stormwater management.
Great Plains
Institute
Add reference to stormwater
management as indicated
8. Strong building section Great Plains
Institute
Comment acknowledged
9. Wind is probably not a good resource w/in Hopkins, might be careful about
including it here
Great Plains
Institute
Ensure that language is
appropriate for community
context.
23
10. In addition to renewable energy targets – consider carbon emissions reduction
targets
Great Plains
Institute
Clarify that the city will follow
the state energy guide to work
towards reducing emissions.
11. On page 74, need to define how “environmentally sensitive” areas are determined 8/28/18
Planning
Commission
public input
Add descriptions regarding
these determinations, some of
which is in appendices
12. Can we commit to having an organic recycling option in place? Language on that
goal is pretty loose.
Nathan
Miller, online
comment
portal
At this time, the city is still
exploring options as to how
this could be provided
Surface Water Management
Incomplete Comments
Number Comment From Proposed Response
1. The Plan needs to include drainage areas, volumes, rates, and paths of stormwater
runoff. This information is required for a local water resources management plan
and can be incorporated by reference if available from another source, but the
source needs to be clearly stated.
Met Council Added information in Section
5.3 and on Figure SW-10
2. The stormwater runoff from the City drains to Minnehaha Creek and Nine Mile
Creek, which are impaired for chloride, dissolved oxygen, and fish and aquatic
intervertebrate bioassessments. The Plan should discuss how the City‘s surface
runoff affects those impaired waters and what the City's role is or will be in fulfilling
current and future TMDL allocations, including related implementation projects and
funding sources needed to address these impairments.
Met Council Section 7.2, Policy 2.8 has been
added to address this comment
3. Finally, the Plan referred to a few figures, but all figures numbered as “WRX.X” are
not found either in the Water Resources Management Plan or in the City's
Comprehensive Plan. Please update or indicate where those figures can be found,
Met Council The plan figure numbers have
been updated
4. Regulatory Authority. There are references in the SWMP to application of NMCWD
regulatory criteria, but the SWMP also appears to rely on implementation of
unspecified city ordinances to protect water resources and mitigate flood risk. The
Nine Mile
Creek
Watershed
Added language to Section 3.4
Permitting, that includes a
statement that the City defers
24
draft SWMP includes a reference to updating city ordinances “to stay compliant
with the NPDES and MS4 permits, ”but otherwise, the draft SWMP observes that
the city, watershed districts, state agencies, Hennepin County and the US. Corps of
Engineers “hav[e] some level of administration responsibility. ”At the same time,
under the heading “Permitting,” the draft SWMP incorrectly summarizes the
existing relationship between NMCWD and the city with regard to exercise of
regulatory authority, stating that NMCWD serves to advise the city as to regulation.
(NMCWD recognizes the SWMP’s clear affirmation, in the Goal 4: Wetlands section,
that NMCWD will continue to serve as the Wetland Conservation Act Local
Government Unit for that portion of the city within NMCWD's jurisdiction.) Other
than with regard to the exercise of WCA jurisdiction, the SWMP does not include a
clear statement of the city's intent with regard to exercise of regulatory jurisdiction
to protect water resources and mitigate flood risk, as required to ensure
consistency with section 6.2 of the NMCWD Plan. Further, if the city intends to
exercise sole regulatory authority itself, the draft SWMP lacks the detailed, specific
updates to the city’s ordinances that would be necessary for NMCWD to find that
the city will protect water resources and prevent flooding to the same degree that
the NMCWD rules do. At a minimum. the SWMP must be revised to include a clear
statement of the city’s intent with regard to the exercise of regulatory jurisdiction
to protect water resources from degradation and mitigate flood risk. (See
Minnesota Rules 8410.0160, subpart 3(4), and the NMCWD Plan, subsection 6.2.1.)
In making revisions to clarify its intent, the city needs to consider subsection 6.2.1
of the NMCWD Plan, which provides a very specific framework to ensure
implementation of a cohesive and protective regulatory program, as well as
specifics on local-water—plan elements needed for NMCWD approval, if the city
intends to exercise sole regulatory authority. The SWMP must not only commit to
submitting ordinances for a determination by NMCWD that they are at least as
protective as NMCWD rules, but also that they will be amended within six months
of notice of amendment of the NMCWD rules. The SWMP would also have to note
that the plan and ordinances would have to provide that variances from standards
adopted to achieve consistency with watershed organization rules will be provided
to NMCWD for review (when applicable to land within NMCWD’s jurisdiction).
(Minnesota Statutes section 103B.211, subdivision 1(a)(3)(ii).) Alternatively, if the
city intends to re-authorize NMCWD to continue to exercise regulatory authority,
its permitting authority over to
NMCWD. Also, a sentence was
added to this section that
states “MCWD and NMCWD
will continue to exercise
regulatory authority in
accordance with Minnesota
Statue 103B.211, Subd. 1 (a) (3)
(ii).”
25
the SWMP should specify how the city will direct potentially regulated parties to
NMCWD to proceed through the permitting process. It is not for NMCWD to direct
the city as to what its decision on this point should be. But the SWMP must be clear
and complete on this point. NMCWD recommends that the city revise the SWMP to
state that NMCWD will continue to exercise regulatory authority in accordance with
Minnesota Statutes section 103B.211, subd. 1(a)(3)(ii). Hopkins always has the
option to amend the plan later and provide for exercise of sole regulatory
jurisdiction by the city if it later determines that such an approach is best.
5. The draft SWMP includes no information on the Nine Mile Creek Bank
Stabilization and Habitat Enhancement Project and the cooperative agreement
between the city and NMCWD that provided the legal framework for its
completion. The amended and restated agreement was fully executed by the
parties on December 7, 2011. Most important, section 3.2.7 of the agreement
makes Hopkins responsible for the ongoing ordinary maintenance of the project;
this commitment should be reflected in this section and must be shown in Table
WR-6 with designation of a funding source for the work.
Nine Mile
Creek
Watershed
This agreement has expired
and is no longer valid and is
therefore no included in the
plan. However, the table has
been updated to plan for
ongoing channel maintenance.
6. The water-quality goal for the SWMP is stated, “Achieve water quality standards in
lakes, creeks, and wetlands consistent with their intended use and established
classification,” which appears to be a reference to state-set goals. But the SWMP
should address how the city will work to achieve NMCWD standards for lakes,
wetlands and the creek with the Nine Mile Creek watershed in the city.
Nine Mile
Creek
Watershed
Section 7.2, Policy 2.8 has been
added to address this
comment.
7. Goal 5: Groundwater. The Goal 5 section on groundwater management policies
could be greatly improved by the specification of specific groundwater-conservation
steps the city will take in implementing its new plan. (NMCWD Plan subsection
7.1.1.) This section also includes discussion of the city’s continued implementation
of its wellhead protection plan, though the most recent update is not included as an
appendix to the plan as it should be. Also, in accordance with the relevant
requirement in subsection 7.1.1 of the NMCWD Plan, the city needs to commit to
providing NMCWD with any future updates of its wellhead protection plan.
Nine Mile
Creek
Watershed
The WHPP is included in the
Appendix. Section 7.5, Policy
5.6 has been added to address
this comment.
8. As noted above with regard to water resource management-related agreements.
Hopkins' commitment to and funding for maintenance of the Nine Mile Creek Bank
Stabilization and Habitat Enhancement Project must be shown in Table WR-6.
Nine Mile
Creek
Watershed
This agreement has expired
and is no longer valid and is
therefore no included in the
plan. However, the table has
26
been updated to plan for
ongoing channel maintenance.
9. Table WR-6 must be revised to include prioritization of the city’s implementation
work, as required by Minnesota Rules 8410.0106. subpart 2E.
Nine Mile
Creek
Watershed
Prioritization has been added
to Table 9.4: Proposed
Implementation Program.
10. 2. Identify MCWD data systems in the local plan and describe their application to
LGU activity in order for the District to ensure that the LGU is aware of these
systems and that they are being used for common intended purposes. Partially
meets requirements. The Summary (Page 2) indicates the City will utilize MCWD’s
updated Plan and notes the City will continue to work to ensure that its goals,
policies and development standards are consistent with MCWD’s Plan and rules.
Functional assessment of wetlands (FAW) is not mentioned in the Plan nor is the
District’s H&H study, although several water resources studies carried out as
feasibility reports are listed in Table WR1.2.
Minnehaha
Creek
Watershed
FAW and H & H study have
been included in Table 5.3
11. 4. Maps of current land use and land use at the LGU planning horizon. Partially
meets requirements. Figure SW—OS provides a land cover map and Figure SW-O8
provides existing land use. A future land use map is not provided in the Water
Resources Management Plan. A future land use plan is included in the
Comprehensive Plan. Please include or reference in the Water Resources Plan.
Minnehaha
Creek
Watershed
The future land use map has
been referenced on Pg. 7,
Section 3.1.
12. 5. Maps of drainage areas under current and future planned land use with paths,
rates and volumes of stormwater runoff. Partially meets requirements. Figure SW-
01 depict HHPLS subwatersheds and City “drainage districts,” but does not indicate
subwatershed flow direction. On page 7 the Plan notes that the City has been
delineated into 60 subwatersheds, but none are depicted on a figure. Figure SW—
OZ depicts drainage districts and storm sewers with sewer flow direction. The
District’s HHPLS study, which encompasses about a third of the City, is not
referenced. Some small areas have been modeled. Please provide stormwater rate
and volume information. Please provide a map of major watershed boundaries and
written description of their geographical and physical characteristics
Minnehaha
Creek
Watershed
Subwatershed flow direction is
shown on Figure SW-01. The
City’s subwatersheds are
shown on Figure SW-08. The
HHPLS study is referenced in
Table 5.3. Rate and volume
information has been included
in Section 5.3 and Figure SW-
10.
13. 6. A stormwater conveyance map meeting standards of the current MS4 general
permit and indicating an outfall or a connection at the LGU boundary. Partially
meets requirements. Figure 5W-02 depicts storm sewers with flow direction. M54
permit requires stormwater flow direction in the pipes, outfalls with unique ID
numbers and geographic coordinates, structural stormwater BMPs and receiving
Minnehaha
Creek
Watershed
NPDES Inventory Map, Figure
SW-08 has been added.
27
waters. These details are not included in Figure 5W—02. City's M54 Permit
indicates the storm sewer system map and inventory are in compliance with M54
requirements — figure from M54 permit should be included in the Water Resources
Plan or at a minimum be referenced; Figure 5W-02 could also be updated.
14. 7. An inventory of public and private stormwater management facilities including
the location, facility type and party responsible for maintenance (e.g., landowner,
homeowner’s association, LGU, other third party). Partially meets requirements.
Table WR1.6 on Page 22 indicates a storm sewer maintenance program and storm
sewer pond maintenance & cleanout as being funded by a stormwater utility fund
—— these are assumed to be for public facilities. Policy 1.3 on Page 12 notes that
the City will maintain and inspect stormwater management facilities to assure they
function as designed. Page 20 indicates the stormwater utility fund is used for
expenses associated with maintaining and improving the stormwater system.
However, private stormwater facilities are not mentioned, and an actual inventory
of public and private stormwater facilities is not presented.
Minnehaha
Creek
Watershed
Section 7.1.1., Policy 1.3 has
been added regarding private
pond management. A pond
inventory table has been
included in Figure SW-08.
15. 8. A listing and summary of existing or potential water resource—related problems
wholly or partly within LGU corporate limits. A problem assessment consistent with
Minnesota Rules 8410.0045, subpart 7, is to be completed for each. This includes
but is not limited to:
• Areas of present or potential future local flooding.
• Landlocked areas.
• Regional storage needs.
Partially meets requirements. An Assessment of Problems that addresses water
resource-related problems begins on Page 17. Water quantity and water quality
issues are the first two problems listed. Per MN Rules 8410.0045 subpart 7,
problems are identified, and funding levels addressed in Table WR1.6 (Page22), but
prioritization of problems to be addressed is not addressed. A specific flooding area
is described on Page 9, and flood control is the stated purpose of the Stormwater
Management Goal (Page11). Page7 states that there are several landlocked areas in
the City that need to be addressed. Storage needs are touched on in the floodplain
management policies (Page16) and with the Stormwater Management Goal on an
on-site basis (Page11).
Minnehaha
Creek
Watershed
The Proposed Implementation
Program, Table 9.4 has been
prioritized.
28
16. 10. Inventory of real property owned by the LGU, including discussion of (i) water
resource issues and opportunities associated with its properties, and (ii) potential
opportunities to coordinate with the District or other partners. Partially meets
requirements. Water resource issues are presented beginning Page 17 — the
Assessment of Problems. However, an inventory of real property (municipal
buildings, lots, etc.) owned by the City is not provided and the water resource issues
within the context of City properties are not addressed. Coordination with MCWD is
included in several portions of the Plan.
Minnehaha
Creek
Watershed
Section 8.8 - NPDES MS4
Permit was added, along with a
copy of the City’s SWPPP in the
appendix.
17. 11. Incorporates the inventory and description of practices from its SWPPP
regarding facilities that it owns or operates and municipal operations that may
contribute pollutants to groundwater or surface waters. Does not meet
requirements. City’s M54 Permit states that the City will complete a facilities
inventory within 12 months of permit extension. An inventory is not provided in the
Plan.
Minnehaha
Creek
Watershed
Figure SW-08: NPDES Inventory
and Figure SW-09: City Owned
Property were added.
18. 12. Include map and inventory of stormwater management facilities, including
responsible party and maintenance condition and schedule. See #7 above.
Minnehaha
Creek
Watershed
Figure SW-08: NPDES Inventory
and a copy of the SWPPP were
added.
19. 13. A description of the LGU’s approach to maintenance of stormwater
management practices constructed in conjunction with private development.
Partially meets requirements. Policy 1.3 on Page 12 states the City shall maintain
and periodically inspect stormwater management facilities and structures. Page 20
states the stormwater utility fund is used for expenses associated with maintaining
the City’s stormwater system, and Table WR1.6 addresses maintenance. However,
the Plan does not describe how the City approaches maintenance of stormwater
management practices in conjunction with private development.
Minnehaha
Creek
Watershed
Section 7.1, Policy 1.3 was
added to address private
stormwater facilities.
20. 14. Information related to the issue of deferred maintenance of public and private
stormwater management practices, to inform a cooperative approach to addressing
the issue (optional). Not addressed. Land Use Planning and Development
Regulation
Minnehaha
Creek
Watershed
Comment acknowledged
21. 15. Identify those areas within or adjacent to the LGU that the LGU has designated
in its CLUP for potential development or redevelopment within the CLUP planning
horizon. This includes planned rezoning, land assembly, and infrastructure
extension or expansion. Partially meets requirements. Summary on Page 2 and
Future Land Use paragraph on Page 4 both indicate that the City is fully developed
Minnehaha
Creek
Watershed
Redevelopment opportunities
have been called out in Section
3.1 Future Land Use.
29
and land use changes will be a result of redevelopment. City’s emphasis on
permitting (Page 5), design criteria (Page 10), stormwater management (Page 11),
and wetlands (Page 14) as they pertain to development and redevelopment are
clear. However, the Plan discusses development and redevelopment in general
terms and does not discuss the areas in which these activities are anticipated. The
City’s Comp Plan indicates that redevelopment plans “focus on several key
opportunity areas in the city, namely the Green Line Extension station areas,
including adjacent areas in Downtown Hopkins and the Blake Road Corridor.” These
too could be called out in this Plan and indicate that those are stormwater
management opportunities.
22. 17. Describe the procedures by which the LGU plans, programs and implements
each of the following:
• Transportation infrastructure
• Sewer and water infrastructure
• Park and recreation land acquisition and management
• Conservation land acquisition and management
The description should include the date of the most recent approved capital
implementation or land acquisition and management program, the frequency of
program updating, the internal procedures to develop and approve the
implementation program and to implement specific actions, and how programming
and implementation is coordinated with other LGU activities.
Partially meets requirements. A Transportation Plan is included as Chapter 8 of the
City’s Comprehensive Plan, and park and recreation planning are outlined in
Chapter 7 of the same document — Plan should reference these chapters/plans
specifically. The example of 13th Ave N (Page 9) provides a glimpse into how sewer
and water infrastructure are planned and implemented; Page 10 addresses how
future storm sewer collection systems are evaluated and designed. Conservation
land acquisition is not addressed and no existing conservation lands are mentioned
— with the City being fully developed, acquisition would not be expected. The date
of the most recently—approved implementation plan is not provided, and no
hyperlink is provided. Table WR1.6 suggests that the City’s stormwater utility fund
has provided and will continue to provide the majority of funding for
implementation.
Minnehaha
Creek
Watershed
Section 9.3, addressing the
City’s Capital Improvement
Program has been added.
30
23. 18. Provide links to small area/redevelopment plans, capital implementation
programs, and land acquisition and management plans listed pursuant to item 17.
Partially meets requirements. Whereas redevelopment is addressed in several areas
of the plan, links for capital implementation programs and land
acquisition/management plans are not provided.
Minnehaha
Creek
Watershed
A hyperlink to the City’s current
CIP has been added in Section
9.3.
24. 19. Evaluation of LGU’s official controls with respect to the integration of water
resource and conservation protection.
• Explain regulatory tools that create incentives to consolidate development
footprint to protect resources (e.g., conservation development, clustering,
density credit, transfer of development rights) –
• Dedication or development fees applied to support acquisition or
consolidation of public park, recreation or conservation land, particularly as
directed toward acquiring or protecting priority water resource areas-
• Setbacks and/or other vegetated buffer requirements with respect to
wetland or other surface waters, reconciled with other terms of its
development code that restrict development footprint
• Tree preservation policy
Partially meets requirements. Page 5 states the City reviews, approves and permits
stormwater management plans on projects that meet the City’s ordinance
requirements and that watershed permits are required for projects that meet
district requirements. Policy 2.1 on Page12 states developments must meet City
erosion control ordinance and Policy 3.2 on Page 13 refers to the same erosion
control ordinance. Goal 6 on Page 15 refers to the City’s ordinance as it pertains to
floodplain management. A summary/table of all the City’s official controls would be
helpful. Policy 4.4 on Page 15 refers to the City’s Engineering Design Guidelines,
which provide standards for protective vegetative buffers around wetlands.
However, details on regulatory tools that create incentives to consolidate
development footprints to protect resources, dedication of fees for park or
conservation land, and tree preservation are not covered in the Plan.
Minnehaha
Creek
Watershed
Table 9.1 -Ordinances and
Official Controls has been
added that show City
ordinances that deal with
wetlands and tree retention.
Being that the City is fully
developed, they do not have
incentives to consolidate
development footprints or park
dedication fees.
25. 20. Identify other regulatory mandates concerning water resources under which the
LGU operates, including LGU's role, responsibility, and compliance status. lnclude
Procedures for enforcement. Specifically addressing the following:
• NPDES MS4 stormwater program
Minnehaha
Creek
Watershed
Information about
nondegradation was added in
Section 8.2.
31
• TMDL program impaired waters referend and TMDL framework
incorporated
• State and Federal anti-degradation requirements
• Safe drinking water act/wellhead protection program
• NFIP, State floodplain management law
• State Shoreland Management Law
• WCA
Partially meets requirements. Water resource management related agreements and
agencies with administrative responsibility in the City are presented on Page2
• Page2 lists the M54 permit as one with which the City must comply.
• Pages 19&20 provide information on TMDLs and impaired waters within the
City; Page 20 underscores the City’s willingness to work with MPCA and
MCWD in the TMDL process.
• State and Federal anti-degradation requirements are not referenced in the
Plan.
• Page15 refers to the City’s Wellhead Protection Plan and outlines the
purpose, goal and policies.
• Pages 4&5 outline the City’s floodplain ordinance and indicate MCWD’s role
in regulation as well.
• Page4 indicates the City does not have a shoreland ordinance; the Summary
on Page 2 suggests this is because the City has no lakes.
• Policy 4.1 on Page 14 indicates the MCWD shall administer wetland
protection and mitigation in accordance with WCA—no changes to that
structure proposed.
26. 22. Describe how regulatory activities are coordinated with the District.
• How are potential permit applicants made aware of District permitting
requirements
• Provide department(s) and positional contact information for regulatory
coordination and how this coordination will be initiated by LGU
Partially meets requirements. Page 5 states that MCWD serves in an advisory role
on development/redevelopment and holds permitting authority—District staff
review development proposals and make recommendations—MCWD permits are
required for projects that meet the district’s rule criteria. Department and
Minnehaha
Creek
Watershed
Information was added in
Section 3.4 about the
permitting process and Table
3.1 was added listing City
Contact Information.
32
positional contact information is not provided, and notation on how coordination
will be initiated is not stated.
27. 24. Sets forth a coordination plan that connects the LGU and District in ways that
efficiently provide for timely coordination.
• Annual meeting to review SWMP implementation
• Transmittal of M54 report
• Describes how the District can receive notice of and consult with the LGU
on its land use planning, infrastructure, park and recreation, and CIP efforts
• Describes when and how LGU will provide notice on small area plans and
other focused development or redevelopment actions
• Regulatory coordination — describe how LGU will share information and
coordinate on the following:
o Pre—application and permit reviews
o Construction site inspection and compliance
o WCA where LGU is WCA authority
o Implementation of District Rules where LGU is rule authority for any
of MCWD rules
• Discussion of coordination opportunities now, on the horizon and/or
requested in the future
Does not meet requirements MCWD Water Resources Plan, Appendix A, Paragraph
5 details an outline for the required, stand-alone, coordination plan. MCWD staff
are available to assist the City in creating this framework.
Goals and Policies of the Plan start on Page 11; Assessment of Problems starts on
Page 17; both sections outline several opportunities for coordination.
• An annual meeting with the District is not proposed.
• Goal 7 (Page 16) discusses holding at least one public meeting per year
to address the SWPPP annual report, but transmittal of the M54 report
to MCWD is not discussed.
• Coordination efforts with MCWD regarding potential projects are set
forth in several areas throughout the Plan. However, the Plan does not
provide details on how the District will receive notice regarding
planning, infrastructure, park and rec, and ClP efforts.
Minnehaha
Creek
Watershed
Policies 7.5, 7.6, 7.7 and 7.8
have been added to address
these comments.
33
• The Plan does not specifically address when and how notice will be
provided on small area plans and other development/redevelopment
actions.
As stated in previous bullet, the Plan either states or suggests that coordination for
the listed elements will occur, but it does not cover how that coordination will look
28. 25. For each element in 24 above, describe when and how the communication will
occur and indicate the department and position for proposed communication plan.
Does not meet requirements. While coordination with MCWD is referenced
throughout the Plan, it does not cover when and how communication will occur
regarding points in #24 above. The Plan does not provide the department or
position responsible for the communication plan.
Minnehaha
Creek
Watershed
Language was added to Section
3.4 Permitting. Policy 7.8 was
added.
29. 28. P. 18, Impaired Waters section
The description “Minnehaha Creek, from Porter Creek to the Minnesota River” is
incorrect. Minnehaha Creek flows from Grey’s Bay to the Mississippi River.
Minnehaha
Creek
Watershed
This was corrected in Section
8.2., Impaired Waters.
30. 29. In a number of locations text referring to figures in the Water Resources Plan do
not match numbering on the figures themselves. There are also figures (such as
SW—03) that are not described or called out in the Plan.
Minnehaha
Creek
Watershed
The figures have been
renumbered and referenced
accordingly in the text.
31. 30. 1. The Plan needs to include drainage areas, volumes, rates, and paths of
stormwater runoff. This information is required for a local water resources
management plan and can be incorporated by reference if available from
another source but needs to be clearly stated
2. The stormwater runoff from the City drains to Minnehaha Creek and Nine
Mile Creek which are impaired for chloride, dissolved oxygen, and fish and
aquatic invertebrate bioassessments. The Plan should discuss how the City’s
surface runoff affects those impaired waters and what the City’s role is or
will be in fulfilling current and future TMDL allocations, including related
implementation projects and funding sources needed to address these
impairments.
3. Finally, the Plan referred to a few figures, but all figures numbered as
“WRx.x” are not found either in the Water Resources Management Plan or
in the City’s Comprehensive Plan. Please update or indicate where those
figures can be found. November 8, 2018
Met Council 1. Subwatershed flow direction
is shown on Figure SW-01.
The City’s subwatersheds
are shown on Figure SW-08.
The HHPLS study is
referenced in Table 5.3.
Rate and volume
information has been
included in Section 5.3 and
Figure SW-10.
2. Addressed in Section 7.2,
Policy 2.8
3. The figures have been
renumbered and referenced
accordingly in the text.
Advisory Comments
Number Comment From Proposed Response
34
1. if available at the time the City formally submits its Plan for review, we request the
City provide the final LWMP in an Appendix with a summary in the body of the Plan,
incorporating any recommended revisions from the Council and two Watershed
Districts’ reviews of the draft LWMP. if available at the time the Plan is formally
submitted, we also request that the City provide the dates that the two Watershed
Districts approved the final LWMP, and the date the City adopted the final LWMP.
Met Council Comment acknowledged
2. Compliance with state rule. The SWMP briefly touches on the basic requirements of
Minnesota Rules 8410.016, but needs to be expanded in several areas; this memo
describes both required and suggested additions, revisions and clarifications to will
be needed for the SWMP to comply with the state rule and achieve consistency
with the NMCWD Plan. The SWMP is short on details, and addresses several
requirements in a very minimalistic manner, and would be improved by the
addition of detail on several points noted below. Performance standards and, areas
and elevations for stormwater storage adequate to meet them are needed.
(Indeed, the SWMP lacks performance standards throughout.) Drainage areas and
volume, rates and paths of stormwater have not been defined; the SWMP notes2
that the city has been delineated into roughly 60 subwatersheds, but no map or
figure showing these areas or description of their features is provided. Water
quality protection methods adequate to meet performance standards are not
identified. NMCWD finds that while the SWMP’s goal and policy statement are
generally consistent with the NMCWD Plan (with certain specific changes noted
below), the city should consider referencing and/or incorporating policies and goals
from relevant watershed district plans, including the NMCWD Plan, to bolster the
scope and comprehensiveness of the city's goals and policies. Further, the city can
significantly improve the comprehensiveness and implementation effectiveness of
the SWMP by clarifying its deference to the exercise of regulatory authority by
NMCWD for the portion of the city within the Nine Mile Creek watershed, as
discussed in more detail below.
Nine Mile
Creek
Watershed
Comment acknowledged
3. Mechanical, typographical specifics. A table of contents and section numbering
would make the SWMP more readily navigated and would facilitate future
reference by city staff and partners in water-resources protection and flood-
mitigation efforts. In light of the lack of such reference points in the draft
Nine Mile
Creek
Watershed
A Table of Contents and section
numbering has been added.
References have been updated.
35
SWMP,NMCWD supplements the significant issues identified in this memo with
comments and suggested (Roman text) or required (underlined) revisions as notes
in the attached Adobe Acrobat file.0 Also, the SWMP as presented in draft form has
confusing and seemingly disconnected references and cross-references to tables
and figures (e.g., there is a reference on page 16 to “Table 1.0," but it appears that
instead, perhaps, the reference should be to Table WR—4; there are references to
Figure SW—01 in a few places in the draft plan but no such figure is readily found).0
The SWMP notes that because the city is effectively completely developed, “future
land[—]use changes will be a result of redevelopment activities,”which strikes
NMCWD as a sound statement of an important background fact. From here,
though, the SWMP often incongruously refers to how “development” will affect
stormwater and flood-flow management. The SWMP should generally address
water resource issues in redevelopment, consistent with the characterization of
future land-use early in the SWMP.
4. Baseline data update needed. The City should consider updating its hydrologic
hydraulic modeling.
Nine Mile
Creek
Watershed
Rate and volume information
has been included in Section
5.3 and Figure SW-10.
Updating the model has been
added as an implementation
item.
5. Land-Use Planning Coordination. Section 1.4 of the NMCWD Plan discusses
NMCWD’s interests in coordinating closely with not only city water—resource and
public works staffs, but with individuals and departments focused on planning and
economic development as well. The stated goal and continued intention is to
ensure integration of water-resource management and protection into city
redevelopment initiatives. The draft SWMP does not address this opportunity, but
NMCWD encourages Hopkins to consider at least a general commitment in the
SWMP that would reflect projects such as the effort to coordinate integration of
stormwater-management features into the construction of and redevelopment
along the Southwest Light Rail corridor.
Nine Mile
Creek
Watershed
Added language in Section 3.1
– Future Land Use
6. NMCWD’s flood-management elevations along the creek should be referenced. Nine Mile
Creek
Watershed
The flood panel hyperlink is
included in Section 3.3.
36
7. Modeling & Studies. A brief description of stormwater issues in the 13th Avenue
area is presented. Other problem areas within the Hopkins, if any, should be
identified and described here as well.
Nine Mile
Creek
Watershed
Comment acknowledged. The
13th Ave summary is provided
in Table 5.3, because it was the
only study with results not fully
implemented.
8. Rain Gages. The draft SWMP states that Hopkins has a precipitation gage located at
the city public works facility. It should be noted that this gage is operated and
maintained by NMCWD.
Nine Mile
Creek
Watershed
Section 6.2 has been updated
to recognize this comment.
9. Goal 2: Water Quality. Policy 2.7 states Hopkins’ intent to adopt policies to
minimize chloride contamination through attention to road-maintenance practices.
The SWMP notes that Nine Mile Creek is impaired for chloride and that a Total
Maximum Daily Load study has been approved for chloride reduction/management.
No further discussion is provided for the implementation of chloride reduction in
Hopkins. The language in the draft SWMP should be expanded to state awareness
of NMCWD’s chloride—management education and training efforts, as well as the
chloride-reduction requirement added to NMCWD’s rules in 2018.
Nine Mile
Creek
Watershed
Section 7.2, Policy 2.9 has been
added to address this
comment.
10. Goal 4: Wetlands. The SWMP mentions that a protective buffer strip must be
retained arounds wetlands. But no specific buffer—width requirements or
standards are identified and no reference to the standards establish in NMCWD
Rule 3.0: Wetland Management.
Nine Mile
Creek
Watershed
Policy 4.4 has been updated in
Section 7.4.
11. Goal 6: Floodplain Management. As required to harmonize the SWMP with the
NMCWD Plan (subsection 7.1.1), the city must commit to coordinating with
NMCWD to develop floodplain information and set consistent flood elevations, as
well as maintaining critical loo-year flood-storage volumes. The SWMP states that
city ordinance will regulate development adjacent to the floodplain districts, but
should reference regulation of land-uses allowed by the city to ensure no
encroachment in or into the floodplain, to ensure no loss of floodplain storage, and
to ensure no structures are built without adequate freeboard. (The policy
statements do address these requirements.) This section of the draft SWMP does
not reference or discuss NMCWD’s floodplain-protection rule or the role of
NMCWD in regulating to mitigate flood risk.
Nine Mile
Creek
Watershed
Comment acknowledged
12. 1. An executive summary stating highlights of the local water plan. Meets
requirements. Plan is organized according to MR 8410 and includes the general
requirements.
Minnehaha
Creek
Watershed
Comment acknowledged
37
13. 3. A summary of water resource management—related agreements, including joint
powers agreements, into which the LGU has entered with watershed management
organizations, adjoining LGUs, private parties or others. Meets requirements. Page
2 lists the agencies that have some level of administrative responsibility in the City,
including MCWD.
Minnehaha
Creek
Watershed
Comment acknowledged
14. 9. A statement of the process to amend the local plan, consistent with Minnesota
Statutes §1038.23S. Meets requirements. The amendment process is covered in a
section that begins on Page 4. This paragraph should clearly set forth the types of
amendments that would be considered minor and would not require WMO review
and approval, and those that would adhere to the statutory amendment process.
Minnehaha
Creek
Watershed
Comment acknowledged
15. 16. List and describe completed or programmed small area plans and similar
planning activities to assess the LGU’s role with respect to defined—area
redevelopment. Meets requirements. No small area plans are listed. However, the
Design Criteria section that starts on Page 9 notes the rate control requirements for
redevelopment. Page 10 states that redevelopment must include facilities to
provide water quality treatment and runoff control. Page 5 notes that MCWD will
serve in an advisory role and permitting authority for redevelopment.
Minnehaha
Creek
Watershed
Comment acknowledged
16. 21. Identify District assistance or coordination that would benefit any of these
programs.
Meets requirements. Coordination with MCWD is stated and implied throughout
the Plan.
Minnehaha
Creek
Watershed
Comment acknowledged
17. 23. Contains an implementation program, consistent with MN Rules 8410.0160.
Meets requirements. Table WR 1.6 on Page 22 provides an implementation plan
with estimated costs and funding sources. Please include priorities.
Minnehaha
Creek
Watershed
Comment acknowledged
18. 26. Identify any District rules for which the LGU wishes to assume sole regulatory
authority, and provide the supplementary information required under Section 3.6.4
of the WMP.
Meets requirements. Policy 4.1 on Page 14 indicates the MCWD shall administer
wetland protection and mitigation in accordance with WCA—no changes to that
structure proposed—no changes to that structure or to any MCWD authority
proposed.
Minnehaha
Creek
Watershed
Comment acknowledged
19. 27. State whether the LGU intends to assume the role of "local government unit"
responsible to implement the Minnesota Wetlands Conservation Act (WCA) or
whether it chooses for the District to assume that role.
Minnehaha
Creek
Watershed
Comment acknowledged
38
Meets requirements. Policy 4.1 on Page 14 indicates the MCWD shall administer
wetland protection and mitigation as LGU in accordance with WCA—no changes to
that structure proposed.
Water Supply
Incomplete Comments
Number Comment From Proposed Response
1. The Council has not yet reviewed the City’s Water Supply Plan that was submitted
to the Minnesota Department of Natural Resources (DNR) on March 19., 2018. if
changes are made to the water supply plan resulting from the DNR's review of the
plan or from changes as a result of revisions to the full comprehensive plan, such as
changes to forecasts, the City will need to provide the Council and DNR with the
updated information when it submits its final Plan.
In the meantime, Council staff recommend that the City develop and include
cooperative agreements for emergency water supply service.
Met Council Comments from the MnDNR
have yet to be received. The
water supply plan has been
revised and will be resubmitted
based on revised population
forecasts provided by the Met
Council.
2. Please also note that Appendix WR2.’ Water Supply, Treatment, and Distribution
uses outdated forecasts that are inconsistent with the forecasts used in the rest of
the Plan. Forecasts must be used consistently across plan elements.
Met Council The water supply plan has been
revised and will be resubmitted
based on revised population
forecasts provided by the Met
Council.
Wastewater
Incomplete Comments
Number Comment From Proposed Response
1. Table that details adopted community sewered forecasts in 10-year increments to
2040 for households and employment.
• This should be broken down by the four (4) discharge points to the
Metropolitan Disposal System:
Met Council The table has been revised as
requested. Text has been
added to detail the
methodology for splitting these
39
o M123
o M122
o Westerly to Minnetonka
o Northernly to Minnetonka
sewer forecasts in lieu of
completing a system wide
sanitary sewer model.
2. An electronic map or maps (GIS shape files or equivalent) showing the following
information
regarding the existing sanitary sewer system.
• Lift stations.
• Existing connections points to the metropolitan disposal system.
• Future connection points for new growth if needed.
• Local sewer service districts by connection point.
• lntercommunity connections.
Met Council Figure has been modified to
illustrate this information.
3. Copy of lntercommunity service agreements entered into with an adjoining
community, including a map of areas covered by the agreement.
Met Council Reference to any
intercommunity service
agreements has been added.
4. Table or tables that provide the following local system information:
• Capacity and design flows for existing trunk sewers
• Assignment of 2040 growth forecasts by Metropolitan interceptor.
Met Council Table WR3.4 lists the data for
the City’s only trunk sanitary
sewer.
2040 growth forecasts have
been assigned by Metropolitan
Council interceptor / lift
station.
5. Describe the sources, extent, and significance of existing inflow and infiltration in
both the municipal and private sewer systems.
• Include a copy of the local ordinance or resolution requiring the
disconnection of existing foundation drains, sump pumps, and roof leaders
from the sanitary sewer system.
Met Council City Ordinance 705.09 is
included and discussed in the
Infiltration and Inflow section.
For added clarity, a hyperlink to
City ordinance 705.09 has now
been added.
6. Describe the sources, extent, and significance of existing inflow and infiltration in
both the municipal and private sewer systems.
• Include a breakdown of residential housing stock age within the community
into pre- and post-1970 era, and what percentage of pre-1970 era private
services have been evaluated for I/I susceptibility and repair.
Met Council An estimate of costs of I&I
based on the sanitary sewer
rate is included on page 8 of
Appendix WR3: Sanitary Sewer.
40
• Include a cost summary for remediating the Hi sources identified in the
community. If previous I/I mitigation work has occurred in the community,
include a summary of flow reductions and investments completed. it costs
for mitigating I/I have not been analyzed, include the anticipated
wastewater service rates or other costs attributed to inflow and infiltration.
A breakdown of housing stock
age pre/post 1970 has been
added. A narrative regarding
inspection of sewer service
pipes during reconstruction
projects has been expanded.
7. Describe the implementation plan for preventing and eliminating excessive inflow
and infiltration from entering both the municipal and private sewer systems.
• Include the strategy for implementing projects, activities, or programs
planned to mitigate excessive I/I from entering the municipal and private
sewer systems.
• Include a list of priorities for I/I mitigation projects based on flow reduction,
budget, schedule, or other criteria.
• Include a schedule and the related financial mechanisms planned or needed
to implement the I/I mitigation strategy.
Met Council Narratives on this subject have
been expanded to respond
more specifically to these
comments.
Advisory Comments
Number Comment From Proposed Response
1. Please review the www.metrocouncil.org/iandi website for current I/I policies and
additional information.
Met Council Comment acknowledged
Parks and Trails
Advisory Comments
Number Comment From Proposed Response
1. Appendix B2, Page 21 - 17th Avenue Bicycle Facility Study: The City may wish to
update their text regarding the 17th Avenue Bicycle Facility Study to reflect its
status, as it currently reads that the study was anticipated to be complete by Fall
2018. In addition, please continue to keep the Park District engaged as the study
evolves.
Three Rivers
Park District
Update with current study
status
2. Appendix D2, page 12 – Text modification requested: The mileage for the following
is confirmed as:
• Cedar Lake LRT Regional Trail: 3.8 miles
• North Cedar Lake Regional Trail: 4.4. miles
Three Rivers
Park District
Update mileage as indicated
41
• Lake Minnetonka LRT Regional Trail: 15.8 miles
ECONOMIC ENVIRONMENT
Economic Competitiveness
Advisory Comments
Number Comment From Proposed Response
1. The Economic Competitiveness section provides “direction for a healthy, robust,
and equitable economy.” Racial equity and economic inclusion are weaved
throughout the goals and policies. Rightly, the discussion highlights the racial
disparities in the economy and strategies to close those gaps. The Center
encourages the City to also include language about the economic opportunities of
racial equity throughout this section. If racial disparities in workforce, business
ownership, income and other areas were closed, the overall economy in Hopkins
(and the region) would be noticeably more prosperous. By focusing on the positive
economic opportunity of equity, the community can better value its diversity and
be optimistic about the future. For resources on the benefits of inclusive growth,
see the Center's website.
Goal 2 in this section is: “Support a healthy, diverse mix of businesses in Hopkins.”
The Center supports the policies under this goal and suggests the addition of a goal
to promote the development of business start-ups by People of Color. Minority
owned businesses grew at 3.5 times the rate of all Minnesota companies in2014;
therefore, a targeted approach to support the development of minority-owned
businesses is a smart public investment.
Goal 3 in this section is: “support the development of a well prepared, diverse
workforce.” The Center supports the policies under this goal and suggests the City
provide more specificity. For example, one of the six policies is “Educate about what
jobs are available at the city.” Educate whom? The Center encourages the City to
focus its workforce outreach efforts on communities that are currently under-
represented in government staff roles. By creating a more diverse city workforce,
Hopkins can advance several goals at the same time.
Center for
Economic
Inclusion
Add policy related to
encouraging business
ownership by disadvantaged
groups, including people of
color, through partnerships.
Revise policy statement
regarding educating about jobs
in the city to reflect that
underrepresented groups will
be encouraged.
Clarify language regarding
ability to live and work nearby.
Add reference to potential
tools such as Community
Wealth Building.
42
Goal 4 in this section is: “promote economic equity in Hopkins, to benefit residents
regardless of identity or background.” The Center suggests the addition of a policy
to “explore the application of Community Wealth Building to build a more equitable
economy.” This framework, which includes strategies such as business conversions
to worker ownership, is a proven driver of racial equity.
2. On page 94 and others, since the city does not directly benefit from adding jobs,
need more emphasis in this section on tax base, including specific goals around
creating sufficient value to sustain public infrastructure and system. In addition to
growing the tax base, should also emphasize using limited resources and
infrastructure more efficiently; also ensure this is reflected as possible benchmark
value in the implementation element.
8/28/18
Planning
Commission
public input
Add policy language around tax
base and resource allocation,
as suggested
3. The Economic environment is missing economic inequality - the rich are getting
richer How do we ensure we are not shifting wealth out of Hopkins? How do we
turn this plan in to a call for action from every different persona of citizen of
Hopkins?
Identifying tech infrastructure investment as something the city can control to help
with economic development is important. 5G is coming. In three or so years there
will be opportunities to enable high-speed broadband wireless across the whole
city. That’s the investment to make. We don’t want VC-backed startups in Hopkins.
We want bootstrapped growth companies. Yes to coworkings spaces. Great equity
points. Overall this plan is incredible and excited me. I think we need to move
quickly to create the community.
The only challenges I have to this already holistic and aspirational plan is how can
this be more comprehensive, inclusive, and aspirational?
Nathan
Miller, online
comment
portal
Comment acknowledged
Downtown
Advisory Comments
Number Comment From Proposed Response
1. On page 100, move “remaining unique” to the top of the list; this is very important
and a key differentiator for Hopkins; central social district is also very important.
8/28/18
Planning
Make revisions and add detail
as suggested
43
Should indicate that the unique downtown is an important marketing tool for
Hopkins – and it keeps getting nicer.
Commission
public input
IMPLEMENTATION
Implementation
Advisory Comments
Number Comment From Proposed Response
1. The Center supports the plan’s implementation section, which identifies action
steps, timelines and potential indicators for every plan goal. The following are
suggestions for strengthening this section in regard to racial equity:
• Page 123 suggests “social and economic disparities” as potential indicators.
The Center encourages the City to identify specific racial disparity indicators
that might be used from the data included in plan (e.g. poverty,
unemployment, labor force participation, household income, health
insurance and homeownership).
• Page 123 also states “Pursue next steps on Hopkins Race and Equity
Initiative, including implementing GARE recommendations.” This is the first
time that GARE in mentioned in the plan; the Center suggests including the
GARE recommendations in an appendix as a reference.
Center for
Economic
Inclusion
Add more information on
potential indicators.
Add explanation of GARE, and
revise language regarding who
this and other tools will be
used.
2. Page Goal Alternative Language
113 H #1 Indicator Language:
• Number of preserved unites of Naturally Occurring Affordable Housing
Units (NOAH) – A specific goal % or numeric goals could be developed
based on current availability of affordable housing.
• Increase the number of units of affordable housing that are either
permanently affordable or long-term housing
Larry Hiscock Goal H #2
Add action step: Explore
opportunities to preserve
NOAH properties and
communicate this goal to
existing NOAH owners.
Recognizing that some NOAH
properties will lose their
affordable status due to
gentrification, attempt to
increase the number of
affordable housing units that
44
have legally-binding
affordability requirements.
3. 113 H #1, 2 Actions:
Utilize innovative mechanism to fund or encourage affordable housing. This could
include tax abatement, establishing a scatter site Tax Increment Finance District or
other value capture method to fund acquisition or create an incentive for landlords
to sell their rental property to a preservation buyer.
Larry Hiscock The City of Hopkins has limited
resources to establish a funding
stream for acquisition or
preservation of affordable
housing while still maintaining
a reasonable tax rate for all
properties. The City will pursue
new funding sources for
affordable housing
development and preservation
through grants, partnerships
and creative solutions as
identified in H#2.
4. 121 QL#3 Actions:
• Partner directly with culturally based organization (including funding) to
build ties with immigrant and refugee communities in Hopkins.
• Hire community cultural liaisons to engage community members.
Larry Hiscock Aligns better with QL#2.
Add action step:
Look for opportunities to
partner with culturally-based
organizations to build ties with
immigrant communities in
Hopkins.
Continue the work of building
relationships with all residents
of the community but
especially with those who are
new to the community or have
not found a meaningful way to
make their voices heard.
5. 110 T#3 Actions: The market is already being impacted by the METRO Green
Line Extension. The $2 billion infrastructure improvement is creating private value
Larry Hiscock The City of Hopkins has a
responsibility to all property
owners (and renters) to keep
45
for property owners. The increased value should be captured to ensure a broader
public benefit beyond property owners and infrastructure.
• Utilize a value capture tool to redirect revenue to develop a grant/loan pool
to fund equitable development projects.
our tax rate reasonable and
affordable. In order to do this,
the City must grow its tax base.
The City will use value capture
tools when it is deemed
necessary to achieve City goals,
on a case by case basis.
6. 106 LU#1 Actions:
All development agreements should include clear benefits for the community:
affordable housing, local hiring, space for small/disadvantaged business, etc.
Larry Hiscock Each development project has
their own set of community
benefits and every project is
reviewed through that lens.
The City of Hopkins ability to
require certain community
benefits varies greatly
depending on the City’s role
and level of financial and/or
land use approvals.
7. 106 LU#1,2 Indicators:
• Number/Percentage of preserved NOAH units
• Development agreements requiring new long-term/permanent affordable
Larry Hiscock The comments are better
aligned with the Housing Policy
section page 113, H#2
8. 126 EC#4 Actions: It is very positive that the City of Hopkins will be
proactively applying an equity lens to its procurement and hiring practices. The City
of Hopkins is also home to and borders by large corporate entities. The City of
Hopkins should proactively engage and partner with corporations in the area to
make the same changes.
• The City of Hopkins will convene and engage local businesses in an effort to
advance racial and economic equity.
Larry Hiscock The City of Hopkins has no
oversight in the hiring practices
of private businesses and
cannot claim to have proven
methods in place around
equitable hiring and
procurement.
9. The Hopkins City Council can take immediate action to encourage the production of
new affordable housing and protect our neighbors who are renting and vulnerable
to being displaced. The Council should act to approve the following:
1. Inclusionary Zoning Policy
2. Just Cause Eviction Requirement
3. Advanced Notice of Sale Requirement
4. Section 8 Protection Ordinance
Larry Hiscock 1. The current draft of the
Comp Plan identifies
pursuing inclusionary
zoning standards under
Housing Policy H#2 action
steps.
46
Please see the attached fact sheets (on Section 8 protection ordinance, inclusionary
housing ordinance, extending just cause requirement, and advanced notice
ordinance). Other communities have adopted these policies. It is time for Hopkins
to do the same.
2. State Statute allows for no-
fault nonrenewal of leases
with only 30 days of
written notice. Cities are
prohibited from adopting
regulations that give up
this right.
3. The proposed Tenant
Protection Ordinance
accomplishes many of the
same goals as an Advanced
Notice of Sale
Requirement.
4. The ability of cities to
prohibit the denial of
prospective tenants on the
sole basis that they use the
Section 8 program to pay
rent is currently being
challenged in the courts.
The City of Hopkins will
monitor the results of the
court action and look for
ways to encourage the
acceptance of the Section 8
voucher program.
10. On page 106, move parking requirements study to short term; any zoning related
items should be in the short term too
8/28/18
Planning
Commission
public input
Make changes as suggested
11. On page 113, move affordable housing implementation steps into the short term
timeframe, rather than medium term – these are high priorities
8/28/18
Planning
Commission
public input
Make changes as suggested
47