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11/24/97 09:28 ECKBERG LAW 4 5959837 N0.063 902
44 Metropolitan Council
Working for the Region. Planning for the Future
•
October 28. 1996
Jane M. Harper
Office of Administration
Washington County Government Center
14900 62nd Street N.
P.O. Box 6
Stillwater, MN 55082 -0006
RE: Washington County
2015 Comprehensive Plan Update
Metropolitan Council Referral File No. 16321 -1
Dear Ms. Harper:
At its meeting on October 24, 1996, the Metropolitan Council considered the Washington County 2015
comprehensive plan update. This consideration was based on a report of the Community Development
Committee, Referral Report No. 96-20. A copy of this report is attached.
The Metropolitan Council adopted the staff report with the following recommendations:
1. That the Metropolitan Council adopt the staff report and inform Washington County that it may put
the proposed comprehensive plan into effect and that no plan modification is required.
2. That the Metropolitan Council recommend that the county work with Council staff and the
townships to plan according to the growth management strategy, and to maintain the Council's
rural area density (an overall 1/10 density calculated on a 640 -acre basis) on remaining
undeveloped land in the review and revision of townships' comprehensive plans.
3. That the Metropolitan Council recommend that the Department of Natural Resources find the
county's proposed rural density for Grey Cloud Island Township inconsistent with the Mississippi
River Critical Area criteria and recommend that the county revise the density to be consistent with
the Regional Blueprint.
Curt Johnson
Chair
CJ.ly
Attachment
cc: Donald Bluhm. Environmental Services
Dick Thompson, Sector Representative
Victoria Boers, Office of Local Assistance, Metropolitan Council Staff
230 Esc nab Street 9e. Paul. MInnerom 56101.1830 18191991.8368 fax 291.0000 worm 29t•0904 Metro Inte Line 2294700
M Aunt opponent/1i alr,pbyr"
11/24/97 09 :28 ECKBERG LAW - 5959837 NO.063 ?03
Community Development Committee Meeting of October 21, 1996
METROPOLITAN COUNCIL •
Mears Park Centre, 230 East Fifth Street, St. Paul, Minnesota 55101 -1634
Phone (612) 291 -6359 TDD (612) 291 -0904 FAX (612) 291 -6550 Metro Info (612) 229 -3780
DATE: October 9 , 1996
TO: Chair and Members of Community Development Committee
FROM: Victoria Boers, Principal Reviewer, Office of Local Assistance (291 -6621)
SUBJECT: Washington County 2015 Comprehensive Plan Update
Metropolitan Council Districts 12 and 16
Metropolitan Council Referral File No. 16321 -1
EXECUTIVE SUMMARY •
ISSUE: Should the Council allow Washington County to put its proposed 2015 comprehensive plan update
into effect?
POLICY IMPLICATIONS: The Council reviewed the proposed comprehensive plan and determined
that the plan will not have a negative impact on, or result in a substantial departure from regional systems
plans and policies.
The county started the comprehensive plan update in 1993, before the Regional Blueprint was adopted in
September, 1994. The county plan references the Metropolitan Development and Investment Framework,
but incorporates policies, forecasts and information from the Regional Blueprint.
The county exercises plannin:.. 1 • . • .:. • . ti only in the unincorporated areas. The county's land
use plan is not s ent with the Regional Bluep 's rural area policy. Th- • . • roposes rural
residential dev• opment on 2.5 an. 5 -acre to aytown, Grey Clout s • d and Lakeland
• • ti•' .' , ` 1 . t is --. w • •u i, e Council's rural density policy o • ne unit per 10 acres •- culated
on a 640 -acre basis.
• • • • • • - e proposed land use in Grey Cloud Island Township is not consistent with the Mississippi
River Critical Area standards. Governor's Executive Order No. 130, designating the critical area, requires
local plans to be consistent with the Regional Blueprint for communities within the Mississippi River
Corridor. The proposed 2.5 - acre development is not consistent with the Blueprint's rural area policy.
The county plan appears to be consistent with the Council's draft growth management strategy (October,
1996 Draft Policy Areas), except f o r the • • • • . = • • : • • •• , • . sland and West
Lakeland Townships. In Bayt• and Grey Cloud Island Townships, the proposed 2.5 an. •cre
development conflicts with the te•y's urban reserve designation, which recommends a 1/40 density. n
West Lakeland Township, -.. • =- ... . , r ... . ' . ' th • . • - • rur•
designation, which reco -nds an overall 1 /10 density
The Council will address rural developme ends, • • • ons of the 1/10 policy for preserving
agriculture and open space, and alternatives to the 1 /10 density policy as a part of the growth management
11/24/97 09:28 ECKBERG LAID 4 5959837 N0.063 1704
strategy. The Council would expect Washington County to amend its comprehensive plan to be consistent , •
with regional policy once a final growth management strategy is adopted.
FUNDING IMPLICATIONS: None,
PREVIOUS ACTIONS: The Council reviewed the county's 1980 comprehensive plan in July, 1982
(Referral File No. 8590 -3) and found the plan consistent with regional systems plans and policies. In
April, 1995 Council staff completed an informal review of the county's draft comprehensive plan update.
DISCUSSION: Washington County's comprehensive plan establishes goals and policies for land use for
the unincorporated areas (townships), natural resources, transportation, recreation and open space,
housing, community facilities and cultural resources. The county allows greater or lesser densities within a
township, provided that the overall average is consistent with the comprehensive plan. The county
encourages new housing that is clustered and designed to maintain open space. The county, with support
from the Council, is developing an open space development (cluster) ordinance to implement this policy.
RECOMMENDATION: That the Metropolitan Council adopt the attached staff report with the
following recommendations:
1. Adopt the staff report and inform Washington County that it may put the proposed comprehensive plan
into effect and that no plan modification is required.
2. Recommend that the county work with Council staff and the townships to plan according to the growth
management strategy, and to maintain the Council's rural area density (an overall 1/10 density
calculated on a 640 -acre basis) on remaining undeveloped land in the review and revision of townships'
comprehensive plans.
3. Recommend that the Department of Natural Resources find the county's proposed rural density for
Grey Cloud Island Township inconsistent with the Mississippi River Critical Area criteria and
recommend that the county revise the density to be consistent with the Regional Blueprint.
2
11/24/97 09 :28 ECKBERG LAW -4 5959837 N0.063 P05
REVIEW OF THE WASHINGTON COUNTY 2015 COMPREHENSIVE PLAN UPDATE
BACKGROUND
Washington County's overall comprehensive plan update guides the county's growth through the year
2015, The county covers 423 square miles and contains 23 cities and 9 townships. With this plan, the
county intends to minimize land use conflicts, preserve property values, preserve existing character and
allow development while preserving the natural resources.
The county held a series of planning workshops to give residents an opportunity to shape the county plan.
County residents strongly endorsed maintaining rural character and preserving open space, and suggested
actively pursuing open space and agricultural preservation in light of development pressures.
The plan's three major components include and use, transportation and linear parks. The plan emphasizes
the boundaries between urban serviced areas and rural =serviced areas in order to reduce sprawl and
preserve openness. This is consistent with the Regional Blueprint's policies for guiding growth. 1
The plan encourages density zoning, rather than minimum lot size to allow greater or lesser density at
different locations of a township, provided that the overall average is consistent with the county plan. The
plan establishes policies for open space development, or clustered housing, which allows limited
development while preserving open space and rural character. The plan identifies urban transition areas
adjacent to the cities of Forest Lake and Stillwater, and supports orderly annexation between cities and
surrounding townships in these areas.
The plan includes a generalized 2013 land use plan map for the entire county. However, Washington
County exercises land use planning and zoning authority only in the unincorporated areas. The county
administers tight ordinances that include zoning, subdivision, shoreland management, St. Croix River
bluffland and shoreland management, floodplaint, individual sewage treatment systems, "201" sewer use,
and mining.
All of Washington County's townships have adopted urban town powers under MN Stat. 368.01, and have
the authority to adopt local comprehensive plans that can be more, but not less restrictive than those of the
county, since township plans must conform to the county plan, The county will implement its plan by
working with the townships to update their comprehensive plans and local controls. According to the Land
Planning Act, the townships should update their local comprehensive plans by December 31, 1998 and
submit them to the Metropolitan Council for review.
AUTHORITY TO REVIEW
The Metropolitan Land Planning Act requires local units of government to submit comprehensive plan
amendments to the Metropolitan Council for review (Minnesota Statute § 473.864, Subd. 2). The Council
received the county's plan update on May 24, 1996. On June 7, 1996 the Council determined the plan
information incomplete for review. The county submitted information on June 27, starting the 60-day
review period (to September 9). On August 8 the county extended the review to October 9, 1996,
Information submitted for review includes: 1) Information summary for comprehensive plan revision , 2)
Washington County Comprehensive Plan Policy Guide to 2015, 3) County Individual Sewage Treatment
System Ordinance, November 3, 1992, 4). Community Septic Systems 201 Program, p, 77 Fig. 14 of the -
County Ground Water Management Plan, October, 1992, 5) Septic Tank Absorption Fields map, June 21,
1996, 6) 201 Sewer Use Ordinance, 7) Letter from J. Harper dated June 27, 1996 responding to
information request, 8) Letter from 1. Harper dated August 8, 1996 requesting review extension, 9) Letter
3
11/24/97 09:28 ECKBERG LRW + 5959837 N0.063 906
from Meg McMonigal, Stillwater Township. dated August 3, 1996 responding to the county plan, 10)
Letter from T. McElveen to J. Harper dated September 16, 1996 requesting review extension. , •
ANALYSIS
Regional Blueprint
Washington County's comprehensive plan proposes to accommodate urban growth, while preserving rural
functions, to achieve compact and cost- efficient development of areas with public sewer and water, to
foster a low - density rural land use patterns in areas without public sewer and water, and to plan for the
county's share of metropolitan growth, Washington County was the fastest growing county in Minnesota
in 1994 (Attachment I).
The county uses the Council's forecasts (dated September, 1994) for population, households and
employment for the years 2000, 2005, 2010 and 2015 as a baseline for the comprehensive plan. In
addition, the plan analyzes population projections from the state demographer's office and from Woods and
Poole, a national data collection and analysis organization The plan identifies the metropolitan urban
service area (MUSA), freestanding growth centers, rural centers, the rural service area and the commercial
agriculture area.
The plan assesses the future viability of commercial agriculture, indicating that commercial agriculture will
continue to decline because of high land values. The highest quality agricultural land is in the.southem part
of the county, in Cottage Grove, Denmark Township and Afton, and will be protected only by polices
supporting agriculture. The county will continue to support enrollment in the agricultural preserves
program. The county will also study creating a transfer of development rights program to preserve
agriculture, open space and sensitive environments.
The future land use plan map establishes low housing densities of one and two units per forty acres in
agricultural areas of Cottage Grove, Denmark Township and Afton (Attachment 2). Densities of 4/40 are
identified in Forest Lake, New Scandia, May, Grant and Stillwater Townships, and are consistent with the
Council's overall 1 /10 density policy
The plan establishes higher densities of 8 and 16 units /40 acres in Baytown, Grey Cloud Island and West
Lakeland Townships. In these areas, the county plan reflects existingg and zoning for 2.5 and 5-
acre lot development, existing development patterns and existing platted lots. The county concluded that
development in these townships had reached a point where the predominant land use pattern could not be
reversed. Nevertheless, the county plan for these townships is not consistent with the Council's overall
1 /10 rural policy. In addition, continued high- density development in these rural townships contradicts the
county's own land use goal of fostering low density development in areas without public sewer and water.
In contrast, the county plan establishes decreased densities of 4/40 in New Scandia and Stillwater
Townships, where current plans allow development on 5 -acre lots. These townships will be required to
reduce rural densities to be consistent with the county plan.
The county plan encourages new housing to be clustered in order to maintain open space and is preparing
an open space development (cluster) ordinance to implement this policy. The county will require townships
to adopt the ordinance.
Regional Systems;
4
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Wastewater Treatment (Larsen)
All or part of several cities in Washington County are within the MUSA. The metropolitan plant in St.
Paul treats wastewater from the county's western cities (Forest Lake, Hugo, Mahtomedi, Oakdale,
Woodbury, etc.) and discharges into the Mississippi River. Another metropolitan facility serving Cottage
Grove discharges into the Mississippi River. The metropolitan facility in Oak Park Heights serves
Stillwater, Oak Park Heights and Bayport, and discharges into the St. Croix River. The remaining cities
and all of the townships currently rely upon individual on -site systems, or package "201" systems for
wastewater treatment.
The county's on -site system management program is not consistent with all program requirements contained
in the Council's Wafer Resources Management Wastewater Treatment and Handling Policy Plan (policy
plan). The county currently allows development in much of its rural area to occur at densities which
exceed the Council's maximum recommended density of 64 units per 640 acres. The Council's current
policy plan calls for the county to implement a post - installation maintenance inspection program that would
require all systems in those areas to be inspected at least biennially. However, the Council is in the process
of revising its policy plan and is proposing to pattern the new recommended minimum frequency of post -
installation inspections after those contained in the Minnesota Pollution Control Agency's (MPCA) newly
revised Minnesota Chapter 7080 Rules. The Council's policy plan update is scheduled to be completed by
January I, 1997. The county will have until January 1, 1998 to modify its program to incorporate
MPCA's triennial inspection requirements. With that change, the county's on -site system management
program is consistent with the proposed Council policy plan update. The Council will provide adequate
time for the county to implement any other changes necessary to make the county's on -site ordinance
consistent with the Council's final adopted policy plan.
The Council's current policy indicates that metropolitan services will not be extended to the rural service
area should individual on -site systems fail. Pollution problems from development activity or inadequate
management of existing sewer facilities must be resolved and financed by the local governments. The
existing metropolitan interceptors and wastewater treatment facilities are not designed to provide any
capacity to rural townships within the county. To avoid on -site system failures and public sewer extension,
the county should consider limiting further subdivision at densities that exceed 4/40 in the townships until
the county's on -site ordinance has been modified to incorporate either the Council's biennial, or the
MPCA's triennial post - installation inspection program. .
The land use section of the plan supports open space design development, or clustered housing in rural
areas, ranging from five to fifty lots in size. The plan includes minimal detail on the criteria for locating
water and wastewater facilities. Facilities could range from individual systems on each lot, to single
systems serving entire clusters. The county will need to revise its on -site ordinance to include design
criteria for such systems. Staff recommends submission of a draft ordinance for review of the consistency
with metropolitan system plans and policies prior to its final adoption by the county.
The Land Use section of the plan states that the St. Croix River cities of Lake St. Croix Beach, St. Mary's
Point, Lakeland, Old Afton Village, and Marine on St. Croix shall continue to "promote compact, small -lot
housing development consistent with their established character and pattern and within the limitations of
thcir sewage disposal systems." However, the Natural Resources section of the plan states that in at least
one of the above cities, Lake St. Croix Beach, about 230 residences continue to utilize on -site systems
which were identified as improperly operating in a study conducted in the 1970's. The plan continues to
say that residents there are pumping their septic tanks as a temporary solution. The plan provides no
indication of how long this "temporary" solution will be sufficient. On -site septic disposal facilities are not
suited for urban development. The continued use of hundreds of improperly operating septic systems in a
3
11/24/97 09:28 ECKBERG LRW -> 5959837 NO.063 P08
localized area immediately adjacent to the St. Croix River presents a potential metropolitan wastewater .
system impact. Staff recommends that the county provide technical assistance to the communities involved
in implementation of county water quality goals and policies. The collective integrity of each community's
on -site systems will need to be addressed in forthcoming comprehensive plan updates which will be
submitted to the Council for review and comment prior to local implementation.
Transportation (Kozlak)
The transportation element of the Washington County plan is thorough and generally consistent with the
Transportation Policy Plan (TPP). The plan analyzes the existing system and future needs to provide
transportation facilities and services in the county through 2015. The plan includes 2015 traffic forecasts,
roadway functional classification, roadway jurisdiction recommendations, needed roadway improvements
and plans for alternative modes, including transit, pedestrians and bikeways. The plan also considers the
location of rail lines, airports and rail/water intermodal facilities.
The plan utilizes the Council's functional classification system. The plan recommends that CSAH 15
remain a minor arterial through 2015 (as designated by the Council) and designates this as a future
principal arterial candidate. Although the Council does not recommend that CSAH 15 become a principal
arterial prior to 2020, it is a logical location for a major north -south route through the county and the
county should not be discouraged from preserving this corridor as adjacent land develops. Even if the road
continues to function as a minor arterial, it is beneficial to minimize access and preserve right of way for
future widening. „
The county's recommendations on roadway jurisdiction are consistent with the Council's philosophy that
principal arterials should be under the jurisdiction of the Minnesota Department of Transportation
(MN/ DOT) and minor arterials under the county. Several trunk highways are identified as potential county
roads. The plan also recommends several adjustments between county and local road jurisdictions.
The plan's transit section is complete and acknowledges that light rail transit (LRT) is not likely to be built
in the county prior to 2015. This is consistent with regional plans, but is a revision from earlier county
plans.
The plan identifies several needed county roadway improvements, many of them in the rapidly developing
areas of Woodbury, Cottage Grove and Stillwater. Roads such as Hinton Avenue between CR 20 and CR
22 should provide alternatives to the principal arterials.
The plan supports pedestrian and bicycle facilities within county road rights -of -way in appropriate
locations although it acknowledges that separate facilities are often not cost effective in low density rural
areas where distances make biking and walking less feasible as transportation modes.
The plan contains access spacing guidelines for various types of roads, an element encouraged by the TPP.
The guidelines are especially important in a growing county where new access points to county roads are
often requested.
The plan also contains several sections which are not required by the Council, such as a traffic signal
ranking system and a cost participation policy. These are important implementation tools for the county to
use with cities and developers, and the county should be commended for including them in its plan.
Recreation Open Space (Stefferud)
6
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The county plan should include the Ceridian Park land acquisition, approved the county Board of
Commissioners in May. The county intends to designate this a regional park, pending the county's
development of the master plan and the Metropolitan Council's public hearing on the recreation open space •
chapter. The plan's recreation open space section is consistent with Council regional park policies and
system plans. The plan should designate Square lake a special recreation feature, not a regional park.
Aviation (Case)
The plan is well done concerning the Aviation system. Some text changes should be made for accuracy.
Figure T -22 ( "Aircraft Noise Zones for Lake Elmo Airport"), page 5 -75, has been deleted from the
Aviation Development Guide and should be deleted in this comprehensive plan. It has been replaced by a
new "Policy Contour" (Fig. T -23) which is included in the 1995 Aviation Guide. The county should review
the Aviation System Statements which were mailed in March of this year.
Other Metropolitan Development Guide Chapters:
Housing (Dougherty)
The plan's housing policies are consistent with the Regional Blueprint. The plan data identifies the current
housing inventory and addresses market and need assessments. The county is not required to participate in
the Livable Communities program. However, several communities within the county are participating in
the program and have negotiated livable communities goals.
Water Management and Nonpoint Source Pollution (Larsen)
The plan states that the county will apply the Council's Interim Strategy criteria in the review of all
proposed development occurring in the county to reduce nonpoint source pollutant loadings in stormwater
runoff.
II
Water Supply Plan (Larsen)
Washington County is not currently required to prepare a water supply plan, because the county is not
responsible for any municipal water supply systems. •
Mississippi River Critical Area (Schenk)
The Mississippi River Corridor was designated a state critical area by Governor's Executive Order No.
130 (as amended) in 1976. The order establishes standards for the preparation of local plans and land use
regulations to implement the goals of the state designation. The order states that the Mississippi River
Corridor shall be managed in accordance with the Metropolitan Council's Development Guide Chapter
(Regional Blueprint).
The Regional Blueprint establishes a rural density policy of 1 /10 for portions of Grey Cloud and Denmark
Townships within the critical area river corridor. The county plan proposes 16/40 densities (2.5 -acre lots)
for Grey Cloud Township. The county should change this density to 1/10 to be consistent with critical area
planning standards.
The Council is an advisory agency to the Department of Natural Resources (DNR). According to the
order. the Council reviews local plans for consistency with critical area planning standards and forwards its
recommendations to it for a final decision.
7
11/24/97 09 :28 ECKBERG LAW 5959837 NO.063 P10
•
School Districts
Washington County's comprehensive plan was submitted to seven school districts. Staff contacted school
district officials to determine how the county plan would impact the school district. School officials
indicated that they received and copy of the county's plan and determined that the plan will not adversely
impact their districts.
FINDINGS AND CONCLUSIONS
1. The Washington County comprehensive plan is well done. The county should be recognized for its
efforts to involve county residents in the planning process.
2. The plan's future land use goals and objectives policies for guiding growth are consistent with the
Regional Blueprint's. In addition, the plan is consistent with regional forecasts for population,
households and employment.
3. Washington County exercises land use planning and zoning authority only in the unincorporated areas.
4. All of the townships have adopted urban town powers and have the authority to adopt local
comprehensive plans that can be more, but not less restrictive than those of the county. The county
will implement its plan by working with the townships to update their comprehensive puns and local
controls.
5. The county land use plan is not consistent with the Council's rural area density policy of 1/10 on a
640 -acre basis in Baytown, Grey Cloud Island and West Lakeland Townships.
6. The Council's revised (draft) Water Resources Policy Plan is consistent with the MPCA 7080 rules,
requiring on -site septic systems inspections every three years. The county must adopt the MPCA's
inspection requirements by January 1, 1998. With that change, the county's on -site system
management program is consistent with the Councils proposed policy plan.
7. The plan is consistent with regional transportation, aviation and housing policies and plans.
8. The county's proposed rural density 16/40 (2.5 -acre lots) for the portion of Grey Cloud Township
located within the Mississippi River Critical Area is inconsistent with the Governor's Executive Order
130, requiring that local plans be consistent with the Regional Blueprint.
•
8
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•
RECOMMENDATION: That the Metropolitan Council adopt the attached staff report with the
following recommendations:
1. Inform Washington County that it may put the proposed comprehensive plan into effect and that no
plan modification is required.
2. Reconunend that the county work with Council staff and the townships to plan according to the growth
management strategy, and to maintain the Council's rural area density (an overall 1 /10 density
calculated on a 640 -acre basis) on remaining undeveloped land in the review and revision of townships'
comprehensive plans.
3. Recommend that the Department of Natural Resources find the county's proposed rural density for
Grey Cloud Island Township inconsistent with the Mississippi River Critical Area criteria and
recommend that the county revise the density to be consistent with the Regional Blueprint.
9
11/24/97 09:28 ECKBERG LAW 4 5959837 NO.063 112
Metropolitan Council Meeting of October 24, 1996 Business Item: C2
tMkTROPOLI'IAN COUNCIL
Mears Park Centre, 230 East Fifth Street, St. Paul, Minnesota 55101
612 291 -6359 TDD 612 291 -090+
REPORT OF THE
COMMUNITY DEVELOPMENT COMMITTEE
DATE: October 22, 1996
TO: Metropolitan Council
SUBJECT: Washington County 2015 Comprehensive Plan Update
Metropolitan Council Districts 12 and 16
Metropolitan Council Referral File No. 16321 -
SUMMARY OF COMMITTEE DISCUSSION:
Committee members discussed the county plan and the inconsistencies between the proposed land use plan; the
current Regional Blueprint rural density policy as well as the draft growth management strategy. The county plan
must be reviewed according to the Council's adopted policies, and although inconsistencies were found regarding
rural density (the plan calls for 2 and 4 units /10 acres, rural policy calls for 1/10 acre on a 640 acre basis), no
system impact or substantial departure from system plans was identified. Therefore, staff recommends that
Washington County be permitted to put this plan into effect.
Inconsistencies between the county land use plan and the urban reserve portion of the growth management
strategy were also noted. Specifically, the draft growth management strategy includes a rural policy area (1 /10
units /acre) and an urban reserve area (1 /40 units/acre). The Washington County plan again calls for 2 -5
units /acre densities, inconsistent with both proposed policy area densities. Staff recommends that Washington
County be alerted to these potential inconsistencies and revise its plan according to the growth management
strategy once it is accepted.
Council member Flower expressed support for recommendation 2 below, that it adequately summarizes the
Council's options at this time, while expressing the Council's concern over these future planning issues.
RECOMMENDATION:
That the Metropolitan Council adopt the attached staff report with the following recommendations:
1. Adopt the staff report and inform Washington County that it may put the proposed comprehensive plan into
effect and that no plan modification is required.
2. Recommend that the county work with Council staff and the townships to plan according to the growth
management strategy, and to maintain the Council's rural area density (an overall 1 /10 density calculated on a
640 -acre basis) on remaining undeveloped land in the review and revision of townships' comprehensive plans.
3. Recommend that the Department of Natural Resources find the county's proposed rural density for Grey
Cloud Island Township inconsistent with the Mississippi River Critical Area criteria and recommend that the
county revise the density to be consistent with the Regional Blueprint.
•
Submitted by:
Kevin Howe, Vice Chair Craig Rapp
Community Development Committee Division Director