East Grand Avenue Overlay District: Sustain Saint Paul written testimony
Ahead of a public hearing at the Saint Paul Planning Commission on April 12th, Sustain Saint Paul submitted the following organizational testimony on proposed changes to the East Grand Avenue Overlay District:
03/14/2024
Public Hearing Testimony to the Saint Paul Planning Commission
RE: East Grand Avenue Overlay District Zoning Study & Proposed Amendments
Chair Grill and Members of the Planning Commission,
Sustain Saint Paul is a volunteer-led, grass-roots organization that champions abundant housing, low-carbon transportation, and sustainable land use in the City of Saint Paul. We submit this public testimony on behalf of the Board, members and advocates that make up our organization.
We applaud PED staff for the excellent work and support the clear intent of the EGAOD Study, which is to remove barriers to economic development along the corridor and enable development that will support small businesses, activate the public realm and enhance the pedestrian experience.
This support notwithstanding, we have several concerns with the existing proposal and wish to offer 3 amendments for Planning Commission & PED staff consideration.
At the close of the Public Hearing, Sustain Saint Paul urges the Planning Commission to resolve that
The Comprehensive & Neighborhood Planning Committee (CNPC) consider and vote on the amendments proposed herein prior to a full Planning Commission vote
PED Staff analyze the proposed amendments and provide CNPC a staff recommendation on the proposed amendments for its consideration
Summary of Concerns
Concern #1: The proposed step back language— requiring a step back of 10’ on all sides of a building above 30’ in height’— is inconsistent with the East end of the overlay district’s existing building stock, and would prohibit new buildings of similar massing/scale to the older buildings on the corridor that define its character.
The appendix (attached at bottom) includes examples of existing apartment buildings on the corridor that do not conform to the proposed step back requirements, and would be prohibited if a developer were to propose building them under the updated EGAOD requirements.
Concern #2: The proposed step back requirements will unintentionally prohibit small or single-lot infill development.
A typical story being 11-12’ in height, the current proposal will result in a required step back for any building over 2 stories. Given the high value of land on Grand Avenue, single parcel / small-scale developments are not economically viable with a step back at 2 stories.
Take a 3-story development on a 65’ wide lot as an example. Without stepbacks, the building pictured below could contain ~12 residential units. Given current land, construction and financing conditions, the project below — recently built in Minneapolis by a small-scale local developer — could be economically unviable.
IMAGE A
Image B on the left below shows the 3rd floor of the building without stepbacks includes two 2-bed units and two 1-bed units . Image C on the right shows the stepbacks as proposed would result in the loss of >50% of the built square footage and two 2-bed units. Under these conditions, no project would be built.
IMAGE B- (2x) 2-bed & (2x) 1-bed units
IMAGE C - (2x) 1-bed units
In a development with the stepbacks pictured on the right:
The cost of land, design, utilities, fire protection and facade would stay the same
The cost of framing would increase with added complexity
The rent generated by the project, which is required by lenders and investors, would decline due to the loss of multiple units
The net effect, according to several developers, and the consultants that provided economic analysis underpinning the City’s 1-4 Zoning Study, is that such a project would not be built.
Sustain Saint Paul believes revisions to the EGAOD must not prevent small or single-lot development, as smaller developments are more likely to have:
Local investors/owners, or at least the absence of institutional investors/owners
Commercial owner-occupants
Smaller, more attainably priced commercial spaces for the kinds of independent businesses that have historically thrived on, and defined the identity of, Grand Avenue.
Proposed Changes:
Sustain Saint Paul’s highest-priority proposed change, Side & Rear Yards: Stepbacks should only apply to front yards, or corner-side yards on projects with >200' of street frontage (e.g. 150' typical lot depth + >50' Grand Ave frontage). Rear yards should not have any step back requirement.
Applying stepbacks to all four sides of a building is incompatible with small-site / single-parcel developments and would prevent any from happening. It is also inconsistent with numerous, cherished precedents along the corridor.
The massing of larger projects has a far bigger impact on light and pedestrian experience. These projects also have greater economic capacity to absorb stepback requirements.
Stepback Distance: Reduce the proposed step back of 10' down to 5'.
A stepback of 10’ (even on just one side of a building) would typically result in the loss of an entire residential unit within a building, something small-site projects cannot economically absorb. Reducing the step back to 5’ would achieve the desired massing reduction from a pedestrian perspective, without reducing interior square footage so much as to eliminate entire residential units.
Change the Stepback Threshold: Increase the current 30’ height threshold triggering a 10’ stepback to a 40’ threshold.
This will ensure 3-story buildings with tall ground floors (typical for commercial space) are possible to build without any stepback and loss of internal square footage required to support small-site development.
The 30’ step back threshold currently proposed is more restrictive than the 39’ (or 36’ for flat or shed roof) currently permitted in lower-intensity H1 & H2 residential districts under the recently passed 1-4 Zoning updates.
In addition to ensuring that a variety of development types remain viable on Grand Avenue, we believe that our proposed changes continue to support the EGAOD’s goal of maintaining a pleasant pedestrian experience.
Sustain Saint Paul urges the Planning Commission to have PED Staff and the Comprehensive & Neighborhood Planning Committee evaluate and vote on these three proposed changes to the current proposed amendments.
Sincerely,
Sustain Saint Paul
Board of directors:
Melissa Wenzel, co-chair
Luke Hanson, co-chair
Galen Benshoof, treasurer
Cody Fischer
Michel Molstead
Zack Farrell
Paul Fiesel
Chris Smith
Karen Allen
Faith Krogstad
Appendix: Examples of existing Grand Avenue buildings east of Virginia that would be prohibited to build under the current proposed overlay district
* 800 Grand Ave, 3 stories (0 setback from both)
* 51 S Avon St, 3.5 stories (0 setback from Grand, ~7ft setback from Avon)
* 805 Grand Ave, 3.5 stories (0 setback from Grand, ~7ft setback from Avon)
* 625, 627, 635, 622, 628, 636 Grand Ave
* 682 W Grand Ave, 3.5 stories (10 ft setback from Grand, 0 setback from St Albans)
* 622 Grand Ave, 3.5 stories (10ft setback from Grand, 10ft setback from Dale, 10ft side setback)
* 628 Grand Ave, 3.5 stories (10ft setback from Grand, 10ft setback from Dale, 10ft setback from neighbors)
* 636 Grand Ave, 3.5 stories (10ft setback from Grand, 10ft setback from neighbors)
* 614 Grand Ave, 3.5 stories (5ft setback from Grand, 0 setback from Dale)
* 625 Grand Ave, 3.5 stories (15ft setback from Grand, ~7ft setback from Dale, 5ft setback from neighbor)
* 627 Grand Ave, 3.5 stories (15ft setback from Grand, 5ft setback from neighbors)
* 635 Grand Ave, 3.5 stories (15ft setback from Grand, 5ft setback from neighbors)
* 657 Grand Ave, 3.5 stories (15ft setback from Grand, 5ft setback from neighbor)
* 661 Grand Ave, 3.5 stories (15ft setback from Grand, 5ft setback from neighbors)
* 669 Grand Ave, 3.5 stories (15ft setback from Grand, 5ft setback from neighbors)
* 42 St Albans, 3.5 stories (15ft setback from Grand, 0 setback from St Albans, 12ft setback from neighbor)
* 30 St Albans, 3.5 stories (0 setback from St Albans, 0 setback from alley, 12ft side setback)
* 24 St Albans, 3.5 stories (0 setback from St Albans, 0 setback from alley, 10ft side setback)
