5. Heller_Unified Development Code CommentsTo: Scandia City Council
Scandia Planning Commission
Ken Cammilleri | City Administrator
From: Brian and Janet Heller (Property owners at 11090 190th St.)
Date: April 20, 2022
To Whom It May Concern,
We have been following the drafting of the Unified Development Code and we have the following
questions and comments we would like you to consider listed below.
We appreciate and thank you for reviewing these items for us.
Sincerely,
Brian and Janet Heller
153.200.030 Subd. 1. A. I. c. describes items that can encroach into setback areas.
In all cases the Development Code states the allowed encroachment distance is 3 feet. We
request that that space be increased to at least 4 feet. For item iii. in particular accessible ramps, should
be allowed a wider encroachment. Handicap ramps should have a minimum space of 36” between rails to
accommodate wheelchairs. Including handrails and allowing some space between the ramp and a
structure, so that the railing and ramp don’t need to be attached directly to the structure, should justify an
increase beyond 36” to a minimum of 48”.
We would also like a new line added for fixed outdoor appliances (Air Conditioner, Exterior Heat
Pump, Generator, Outdoor Wood Boiler, Hot Tubs, etc.) to be included in the list of items that can extend
into the setback area. These items can be added to a residence well after it has been built and it would be
nice to know if these would be permitted to be added or if a variance or conditional use permit would be
needed to add these to a Primary or Accessory Structure.
Table 153.2002030-20 Accessory Building Dimensional Standards Table
This is just an item to ponder. We don’t have a specific recommendation. This table designates
maximum aggregate sizes for buildings/ structures on various sized lots. Table 153.200.030-1 Summary
of Dimensional Standards for Base Zoning Districts lists lot coverage maximums, the most restrictive of
which is 25%. For larger parcels it is extremely difficult to come close to that percentage let alone reach
it.
As an example: You have a 10 Acre property with 3,000sf home footprint, 1,200sf attached
garage, 6,000sf in accessory buildings, and 6,000sf driveway (20’ X 300’). That amounts to 16,200sf of
coverage which is only 3.72% of the 10 acre parcel. If in that same category you have a 19.99 acre parcel
the percent covered is cut in half. A person would need to add a parking lot or a lot of sidewalk to
approach the 25% maximum. The categories of 20 acres and above allow somewhat larger non-
agricultural accessory structures, but they allow unlimited agricultural accessory buildings (which would
actually be limited by the 25% coverage maximum).
The item to think about is why are accessory structures limited to the sizes they are on larger lots
when it is difficult to get 25% coverage. Either the accessory structures are held to an unreasonably small
size or the 25% coverage isn’t a realistic number for large lots.
153.300.030 USE SPECIFIC REGULATIONS
Subd. 1
(II) Wind Energy Conversion Systems (WECS). Wind energy conversion systems must comply
with the following standards.
VII. Rotors may not exceed 26 feet in diameter and must have a clearance of 30 feet
over any tree or structure within the parcel where it is located.
For clarification: Does this mean that the bottom of the rotor at its lowest point must rest 30 feet above
the top of all trees on the property? If it does, this seems to conflict somewhat with the tree standards
stating the need for major overstory trees. For example a red oak can reach a height of 75’ and a silver
maple can reach a height of 80’. For mature trees of these heights, the highest allowed part of the WECS
(100’) may not be 30’ above the top of the tallest trees on the parcel, let alone the lowest part of the rotor.
If only a clearance of 30’ is required and elevation is not important then perhaps the word “from” would
be more appropriate than the word “over” in the section above in bold.
153.400.030 SITE AND BUILDING DESIGN
Subd. 3. Building Type and Materials.
(A) General Standards.
III. Finished Building Material for Principal Structures.
For clarification: How does this section relate to exposed (above grade) foundation walls, primarily
poured concrete or concrete block? Do exposed foundation walls need to be covered in a finish
material?
153.400.040 CHARACTER AREA STANDARDS
153.400.040 Subd. 1. B.
I. g. and II. d. Fences
This seems too restrictive. For sufficiently large yards that have few or no trees, nearly any fence
behind a structure can be seen by moving far enough to the side. This would effectively remove chain link
as being an option for many large yards, even when placed in the backyard. Chain link fencing provides
protection and containment for pets while allowing a minimally obstructed view through the fence. Can
set back or other placement requirements (eg. 200’ or more from right of way) be established to allow the
use of all fence types in large yards?
153.400.060 LANDSCAPING, BUFFERING AND FENCES
153.400.060 Subd. 2. (D) III.
Note: The following may not be applicable as residential subdivisions and commercial properties tend to
be smaller.
Table 153.400.060-1. Required Number of Trees
This table provides a count of major overstory trees required, on landscape plans. These
requirements are generic. Lot size and usage is an important factor. Properties in Rural Residential
Neighborhood, Village - Historic Core and Village - Historic Center may be too small to support 5 major
overstory trees per residence (when fully grown), whereas the other zoning districts usually have larger
parcels that can handle the number of trees more easily. Conversely a 40 acre parcel should be able to
support many more than the 5 trees per residence specified with a possible major exception if the land is
used for growing crops or raising livestock (particularly livestock that graze). If the city wants standards
for tree coverage it should match the character of each of the underlying zoning districts.
If plans are only required for small lots this may never be an issue, but if plans are ever required
for large lots this table may be inadequate.
153.400.060 Subd. 2. (G) Minimum Planting Size (minor formatting comment)
The name of this article is misleading. It has the following 2 tables listed underneath.
Table 153.400.060-2. Minimum Planting Size Required
Table 153.400.060-3. List of Recommended Plant Materials
Subheading I. talks about species. If subheading I. was broken down into overstory, understory,
ornamental or shrub, species I would understand it being under (G), but as it is written the second table
seems like it should be a separate clause. Maybe (G) would be better titled Plant Selection and Minimum
Quantities.
153.400.060 Subd. 2. (G) IV. Parking Lots/Planting Islands.
Are the trees in this section in addition to those required in Table 153.400.060-1. Required
Number of Trees?
Other Notes, Comments and Concerns
Can the word agricultural be defined?
Different places define the term agricultural differently. Raising livestock and annual sow and
harvest crops are usually included in that definition, however activities like beekeeping and collecting
honey, tapping trees and producing syrup, harvesting trees and producing lumber and/or firewood are
some activities involving the land that are often overlooked. We would appreciate it if the definition
would include these and similar activities that are sometimes overlooked as agricultural activities.
Is there a difference between “Accessory Structure” and “Accessory Building”?
The Development Code uses “Accessory Building” and “Accessory Structure”, often in close
proximity. “Accessory Use or Structure” is defined however “Accessory Building” is not. If there is a
difference it would be nice to have both terms defined. If there is no difference a consistent phrasing
should be used throughout the Development Code.
References to tables.
There is/ are:
1 reference to “Table 1” but can’t find a table labeled “Table 1”.
11 references to “Table 2” but can’t find a table labeled “Table 2”.
2 references to “Table 6” but can’t find a table labeled “Table 6”.
Can language be added to facilitate garbage and recycling pickup on large lots?
For large lots where the houses are set back a large distance it would be nice to have an approved
means to store trash and recycling containers near the street. In the winter especially, hauling these carts
long distances increases the chances for injury due to slips and falls. It is easier and safer to transport
individual bags of waste in a vehicle down the driveway to the containers than it is to walk the containers
down the driveway. Having the carts in an enclosure, especially one with a top or roof, also provides an
impediment for animals (rodents and bears) getting into the carts. We propose allowing an additional
structure on parcels with driveways over 100’ to house and obscure from view, trash and recycling cans,
to be placed near the driveway and within 20 feet of the right of way. The size should not exceed
whatever is required to house both a residential trash cart and a residential recycling cart that the city or
private waste haulers usually provide (approximately 3’ deep X 6’ wide’ X 5’ tall). The design and
materials would be up to the city to decide to balance homeowner safety with neighbors’ aesthetic views.
[A similar allowance may be appropriate for homes with driveways exceeding a specified slope.]
Can language be added to permit construction of an Accessory Structure prior to the Primary
Structure?
A proposal for this would be to allow an accessory structure to be built prior to the primary
structure with the understanding that a primary structure must be constructed within 36 months of the
accessory structure being approved. This could allow 24 months to store equipment to prepare the land
for construction of the primary structure and allow people a space to store items from an unrelated
property/ residence in preparation to sell that property/ residence. The other 12 months is a reasonable
amount of time for permitting and construction of the primary structure. If after 36 months from approval
of the accessory structure, the primary structure has not been completed, then the property would be taxed
at a rate assuming all unfinished space on the property is finished. If the accessory structure has not been
completed then the parcel would be taxed at a rate equivalent to if the accessory structure submitted in the
building permit were complete and fully finished. Proper assessment of the property and taxes would
begin once the primary structure is completed and duly inspected and passed.
Note: We have no idea whether a tax penalty of this kind can be levied on a parcel for non-compliance of
building permits.
Current Development Code
Chapter 2, Section 3.2, (2), of the existing development code states that
(B) No detached accessory structure, including storage sheds, shall be located closer to the road
right-of-way in relation to the front lot line than the principal building on a lot unless the following
conditions are met:
2. The accessory structure is located on a lot of five (5) acres or more and is placed at least 200
feet from the road right-of-way;
We have been unable to find language in the newly proposed Unified Development Code that
describes this exception to allow Accessory Structures to be built closer to the right of way than the
Primary Structure. We believe this exception should be in the new code. For large properties, having
freedom to place the Accessory Structure closer to the right of way than the Primary Structure will allow
greater flexibility in how owners place their buildings.