I am posting the letter to the County Board that the City Council sent regarding our concerns about the proposed Comprehensive Plan.
The City of Isanti has received notification that the Isanti County Board of Commissioners will be holding a public hearing on January 26th, 2009, on the Draft Isanti County Comprehensive Plan. The City of Isanti City Council has reviewed and discussed the proposed plan. By consensus, the City Council would like to express the following concerns and provide comments on the proposed Isanti County Comprehensive Plan:
1. In review of the draft plan, the charts and graphs; which are the basis for the plan utilize data and statistics that were collected in 2000. Isanti County, along with its cities and townships, has seen significant growth and development since this information was collected. The data provided within the plan no longer provides an accurate representation of Isanti County. For instance, on page 23 Table 4.6 Population Profiles, the City of Isanti has exceeded the population projections noted for 2030. As a result, much of the data provided within the plan is already “out dated” before the plan has even been adopted or implemented.
The City of Isanti had expressed this concern in a memo, which was sent to the Isanti Board of Commissioners on April 16th, 2008. It would appear that this particular concern has gone unrecognized at this point. Again, the County should consider and obtain more up-to-date information from other sources, which more accurately reflects the changes that have taken place within the County.
2. The City had requested a Future Land Use Map, which would show the proposed locations of the land use designations provided for within the Comprehensive Plan. The maps that were sent to the City would appear to be Existing Zoning Maps for Isanti County. As a result, the City of Isanti does not know where or how increased residential densities, commercial or industrial districts may affect future development within our expansion areas. In addition, the maps provided do not contain a key, depicting and clarifying what the various colors represent. The City also has concerns regarding the maps accuracy as they pertain to the City boundaries for the City of Isanti. Overall, it is very hard determine what is being represented on the maps.
3. The City continues to have concerns regarding the proposed density increases and the potential location of these increased residential density developments as well as the additional commercial / industrial development that is being proposed. As mentioned in the City’s previous concern memo to the Isanti Board of Commissioners, with increased residential densities, commercial and industrial development; there will be a higher demand for County services; to include, infrastructure, police and fire protection, etc. When growth and development occur within the County, everyone pays. City residents and businesses pay taxes to both the City and the County. Those living within the County, pay taxes only to the County. The residents of the City of Isanti will want to know what the County is willing to give to support the type of growth that is being promoted. The County needs to ensure that those individuals living within the City limits are not unduly burdened and required to pay for the additional growth and development of the overall County. The County must be able to ensure that it is able to pay, its own way, for the additional growth and development that has been proposed.
4. The City has concerns regarding how the Rural Service Centers will be administered under the new plan. In one portion of the plan, the “existing rural service centers will retain current ordinance status and requirements”; however, later within the document new standards are to be developed for this particular district. The understanding is that these areas are to expand and new uses are to be added. Where are they going to be located? What types of uses will be permitted?
5. The proposed plan would appear to have the sentiment that the Comprehensive Plan can be changed on a whim to provide areas for Commercial and Industrial development, on a case by case basis. While the market and goals of the County may change over time and amendments may be necessary, the intent of the Comprehensive Plan is to provide decision-makers and staff with a guide for making future development decisions. In many ways, the language provided within the County Comprehensive Plan would appear to allow outside parties to drive the future development of the County. As a result, business and commercial development could locate almost anywhere conditions seem warranted.
6. There is a section that focuses on Smart Growth, its definition, history, rationale, and principles (begins on page 32). This would appear to be more of a reiteration of information provided within a planning textbook. While this information is helpful, there does not appear to be a rational reason as to why it is necessary to be included within the plan itself. The City questions how the information actually shapes the plan.
7. Again, the process in which the plan was developed is rather disjointed. The land use portion of the plan has been drafted after the adoption of the Transportation Plan. The land use plan has proposed increased residential densities, rural service centers with different types of uses as well as expansion of commercial and industrial areas. Transportation and land use are intertwined. The City questions whether the transportation portion will be able to support the land uses and density ranges that have been proposed.
This point had been questioned previously, the response from the County in a memo dated 4.22.2008 was that “this comprehensive plan update references the preparation sequence of land use and transportation plans and the desire for land use to inform planned and future transportation decisions. It is anticipated that the Isanti County Transportation Plan 2006-2030 will require modification to respond to changes in land use.” Obviously, there are concerns that the development will take place without having a new transportation plan to accommodate such growth.
8. The County has proposed residential densities that could potentially double within future City of Isanti growth areas. This increase in densities will make it cost prohibitive for the City to extend utilities (sewer and water) within the future to these areas. Rather than trying to coordinate and work with the future development recommendation of the City’s Comprehensive Plan, the type of development proposed by the County would appear to work against the City’s future plans.
9. Much of the information provided within the Comprehensive Plan will require amendments to the Zoning Ordinance and / or Subdivision Ordinance, to ensure that the County is developing in accordance with the goals and objectives of the plan. Will the County enact a moratorium on development? The County has spent a great deal of time drafting this plan. Rules and regulations should be in place to guide development in the direction that has been identified within the plan.
10. The City strongly encourages that definitions be added, which accurately describe and characterize the planning and land use concepts that have been presented and identified within the plan. In recent general discussions of the County Board of Commissioners concepts or words, such as “conservation easement” have been provided; however, there are various ideas or perspectives as to what is actually meant or intended by this term. Providing definitions or explanations for these terms within the plan would be helpful to those administering the plan, as it provides direction when making difficult land use decisions.
The City of Isanti City Council would like to thank the Isanti County Board of Commissioners for considering their comments and concerns regarding the proposed Isanti County Comprehensive Plan. If the Board has questions or concerns surrounding any of the comments provided within this memo, please contact Isanti City Hall at (763) 444-5512.