08.b2 Solar Ordinance Amendment CC Staff Report
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Memorandum
To: Scandia City Council Reference: Lubke Ordinance Amendment –
Solar
Copies To: Brenda Eklund, Clerk
Ken Cammilleri, City
Administrator
Michael Lubke, Applicant Project No.: 18108.000 Lubke Ordinance
Amendment - Solar
From: Evan Monson, Planner Routing:
Date: December 16, 2021
SUBJECT: Request to amend the Development Code regarding requirements of solar
energy systems and to allow distribution solar energy systems within the
Shoreland Overlay zoning district
MEETING DATE: December 21, 2021
APPLICANT: Michael Lubke
ITEMS REVIEWED: Draft of Ordinance, and redlined draft with proposed changes from Applicant
DESCRIPTION OF THE REQUEST
The applicant is requesting to make some changes to the current zoning requirements for solar energy
systems. Such systems, referred to as ‘SES’ in the Development Code, were last updated in Ordinance
#210 in 2019. The requirements for a SES are located within Chapter Two of the Development Code. The
latest changes in 2019 defined two different types of solar energy systems: a local SES and a distribution
SES. A local SES would serve a customer on-site, such as a homeowner having a solar panel on their
roof to power their house. A distribution SES would be a larger, commercial sized project that would serve
power to customers off-site. ‘Solar Farms’ or ‘solar gardens’ are generally the terms used to describe
these larger solar developments.
The applicant is proposing multiple changes to the requirements for solar energy systems. The first
change would be to permit distribution SES in areas within the Shoreland Management Overlay District
as a conditional use, if the site is able to meet certain criteria. Currently, no distribution SES are permitted
within the Shoreland Overlay. The second change would be to revise the screening requirements for
distribution SES to include a ‘scenic canvas’ and other options that may help alleviate issues with
screening and visibility. Other changes would include allowing the growing of crops underneath solar
panels; currently grasses and native plantings are typically installed under solar panels.
The Planning Commission reviewed this request at their meeting on December 7th. There was some
discussion on the specifics of the text with minor changes recommended. The Commission recommended
approval of the ordinance amendment, with the changes recommended at the meeting. Included for
review is the latest redlined draft of the ordinance, as well as a ‘clean’ copy.
Lubke Ordinance Amendment Staff Report December 21, 2021
Scandia City Council Page 2
STAFF COMMENTS
Comments from the DNR
As part of the amendment request would be to allow distribution solar in areas within the Shoreland
Overlay, the Shoreland Management chapter of the Development Code would need to be amended.
Amendments to the Shoreland Management regulations requires notification of the proposed change be
sent to the state Department of Natural Resources (DNR) for review and comment.
The city sent copies of the proposed change to the DNR for review. The DNR has a ‘model ordinance’ for
municipalities to adopt and use for shoreland management regulations, which our ordinance is based off
of. They also use the model ordinance to compare proposed amendments to. The DNR’s model
ordinance does allow solar facilities as a principal use on any lands within the shoreland overlay through
a Conditional Use Permit (CUP). In discussions with the area hydrologist, allowing the proposed changes
as a conditional use is preferred. The changes/revisions that the DNR would recommend would be to
clarify the amendment language to ensure parcels zoned AG C around Falls Creek are not opened up to
Distribution SES, and to clarify that the scenic canvas is a temporary/short-term screening option to use
while vegetation and plantings grow to their intended sizes. The DNR sent over a conditional letter of
approval to the city on December 15th, concurring with the comments made by the area hydrologist.
Comments from Attorney regarding spot zoning
Staff discussed the proposed changes with the City Attorney. The criteria requirement for allowing
distribution SES in certain areas within the Shoreland Overlay was noted as being unique and different
than that used in other communities. Since the proposed change would allow the use in more than just an
individual parcel, the request would not be considered spot zoning.
EVALUATION OF REQUEST
Changes from Current Requirements
The proposed changes would be different than the current regulations on the books. The biggest change
would be allowing distribution solar development on parcels within the Shoreland Overlay zone as a
conditional use if certain criteria are met. That criteria would be:
The waterbody within the Shoreland Overlay District must be completely encapsulated by land
within the AG C zoning district.
o Waterbodies that are completely encapsulated by land within the AG C zoning district but
within the St. Croix River District would not meet the above requirement.
All structures and facilities must not impact views from public waters, and views to water bodies
from public throughways through screening requirements found in subsection (4) of this Section.
Vegetation removal shall follow the requirements of Chapter 5, Section 8.2, and Chapter 2,
Section 3.11 of the Development Code.
This request would open up a number of parcels to potentially having distribution solar. On the following
page is the areas that would be meeting the newly proposed criteria:
Lubke Ordinance Amendment Staff Report December 21, 2021
Scandia City Council Page 3
Above, Left: Multiple parcels near the intersection of Manning and Scandia Trail. Above, Right: Multiple parcels east of Lofton
Avenue, south of Bone Lake and 228th St.
Left: Multiple parcels near 230th St, located east of Nolan
Avenue and west of Oldfield Avenue.
Lubke Ordinance Amendment Staff Report December 21, 2021
Scandia City Council Page 4
While these parcels, under the proposed ordinance, could be used for solar development, such a use
would require a conditional use permit (CUP), so review and approval would still be required from the
Planning Commission and the City Council. Any solar development would also have to follow applicable
setbacks from wetlands and waterbodies, which could keep the number of potential applications for these
areas low.
The proposed changes also include new requirements for screening of distribution SES. The current
requirements use a combination of setback distances, vegetation, berms, and landscaping to screen the
developments from view. The applicant is proposing an additional item to help better screen distribution
SES, a ‘scenic canvas’. Said canvas would provide immediate screening, and would be attached to the
fencing placed around a distribution SES. The canvas would be in place for a set period of time, so as to
provide immediate screening while vegetation and landscaping installed on the site are growing. For
previously approved projects, vegetation and landscaping takes time to grow to their full heights, which
can result in inadequate screening while the plantings grow.
The final change proposed in the ordinance amendment is to allow additional planting options for the
ground below a solar array. The option of agricultural planting, or deep rooting pasture plantings, is
proposed by the applicant as an alternative option in addition to the current requirement. Currently, the
city requires deep rooted, native grass and pollinator seed mix be planted in the areas not used for
equipment.
AMENDING THE DEVELOPMENT CODE
Chapter One, Section 5.0 of the Development Code includes the criteria and required process for
considering amendments to the Development Code, as well as amendments to the Comprehensive Plan
(text or map amendments) and the Zoning Map.
As a legislative action, the city has some broad discretion when reviewing amendment requests. When
reviewing an amendment to the Development Code such as this, the City Council should consider
possible effects of the proposed amendment(s) on the community. Chapter One, Section 5.1 of the
Development Code notes that judgment or review of ordinance amendments should be based upon (but
is not limited to) the following factors listed below:
5.1(5)(A): The proposed action shall be considered in relation to the specific policies and provisions of
and shall be consistent with the City Comprehensive Plan, including public facilities and capital
improvement plans.
5.1(5)(B): Whether the proposed action meets the purpose and intent of this Chapter or in the case of a
map amendment, it meets the purpose and intent of the individual district.
Lubke Ordinance Amendment Staff Report December 21, 2021
Scandia City Council Page 5
ACTION REQUESTED
The Scandia City Council can do one of the following:
1. Approve
2. Approve, with changes
3. Deny, with findings
4. Table the request
RECOMMENDATION
The recommendation of the Planning Commission was for the City Council to approve the ordinance
amendment request.