N4MN City Survey Responses (Detailed)

The city of Minneapolis is revising its zoning code for the first time since 1999! Zoning code determines what kind of buildings can be built in different parts of the city, as well as how big those buildings can be. Minneapolis passed the Minneapolis 2040 Comprehensive Plan in 2018, and the Land Use Rezoning Study is an important part of implementing that plan. The city has released a draft of the new zoning code for public review, and they are accepting comments in a survey.

Figure 1: New Primary Zoning District Map for Minneapolis. Notice how much of the city is made up of the three different shades of orange, Urban Neighborhood.

The survey primarily focuses on what uses (such as a restaurant, or housing) are allowed in different primary districts and we’ve included some links below if you’d like to review the code yourself. The full draft of the code is 384 pages long, and the survey is quite dense, so N4MN has been busy analyzing the code and figuring out its highlights and shortcomings to help fill out the survey.

City Timeline:

  • January 12 thru March 26 – Public Review Period
  • Feb 15 – Virtual Public Meeting (Already happened, view slides here)
  • April 24 – Planning Commission Public Hearing
  • May 16 – BIHZ Committee Vote
  • May 25 – City Council Vote

Useful Links:

A handful of N4MN volunteers have been working to come up with responses to the survey. We’ve used a color-coded method to make it clearer what the prompts and questions from the city are. We suggest you look at our responses while you work on your own version of the survey.

City Prompt

City Question

N4MN Response

1. Minneapolis 2040 establishes goals to Eliminate Disparities, accommodate More Residents and Jobs, and increase Affordable and Accessible Housing. To help meet these goals, reduce the number of cost-burdened households, and address income inequality between Black, Indigenous, People of Color (BIPOC) and White communities in Minneapolis, the comprehensive plan calls for increasing housing supply, and increasing diversity of housing types throughout the city. Each district reflects the number of units allowed on a property, and the type of congregate living allowed.

The UN1 Urban Neighborhood District allows for small-scale residential uses. It is applied in locations with Urban Neighborhood future land use and Interior 1 built form zoning.

The UN2 Urban Neighborhood District allows for small to moderate-scale residential uses. It is applied in locations with Urban Neighborhood future land use and Interior 2 and Interior 3 built form zoning.

The UN3 Urban Neighborhood District allows for moderate to large-scale residential uses near transit routes and METRO stations. It is applied in locations with Urban Neighborhood future land use and non-Interior built form zoning.

Where should each of the UN districts (UN1, UN2, and UN3) be applied?

UN1 and UN2 districts should be combined in their current state (more below).

What are the actual differences between the proposed UN1 and UN2 primary districts?

There are only four uses that are prohibited in UN1, that are allowed in UN2:

  • Existing fraternities/sororities – Conditionally allowed
  • Off-site parking for multi-family – Conditionally allowed
  • Single-room occupancy (SRO) housing – Permitted
  • Multi-Family Housing (4+ units) – Permitted

The first two uses will be rare. There aren’t many fraternities (that I am aware of) in UN1 spaces, but UN2 prohibits the construction of new fraternities or sororities. Huge apartments that need massive off-site parking will not be built on parcels where UN1 is shown right now due to the limitations of the built form overlay districts.

There is no reason to restrict the type of housing in the outskirts of the city (where UN1 is applied) to only 1-3 dwelling units. Generally, UN1 districts are applied in Interior 1 built form overlay districts, which restrict all dwellings to 2.5 stories and a Floor Area Ratio (FAR) of 0.5, regardless of how many dwellings it has.

Allowing SRO and small scale (2.5 story max) multi-family housing increases housing diversity throughout the city without allowing huge developments. The city should not be regulating the scale of buildings through the uses table, when they already do so through the built-form regulations via FAR allowances, building heights, yard setbacks and minimum and maximum lot sizes. In the draft’s current state, it regulates scale through both uses and built-form regulations and excludes important types of missing middle housing from large swathes of the city (middle housing is a large part of the city’s implementation plan). Built form Interior 1 districts already prevent 4+ dwelling units from being built on a lot smaller than 9,000 sqft (typical lot is 5,000 sqft).

2. Minneapolis 2040 calls for Urban Neighborhood areas to allow “small-scale institutional and semi-public uses (for example, schools, community centers, religious institutions, public safety facilities, etc.) scattered throughout.”

Which institutional and civic uses should be allowed in residential areas?

Neighbors for More Neighbors believes that the proposed “institutional and civic” uses within Urban Neighborhoods are sufficient, and applauds the city’s inclusion of childcare centers in Urban Neighborhoods.

3. Transit built form districts are applied in parts of the city with the highest demand for housing, often with the most frequent transit service. To reflect those pressures and needs, Transit built form districts already require minimum development intensity of 2-, 4-, 6-, or 10-stories. The land use rezoning study offers another opportunity to maximize density and in areas with the best access to mass transit.

Should Transit built form districts allow new dwellings with less than 4 units?

No, Transit built form districts should not allow new dwellings with less than four units.


Transit built form overlay districts occur near rapid transit, where there have been significant transit investments. Transit works best near medium to high density residential uses as well as near commercial destinations on ground level. Allowing new dwellings with less than four units on these parcels would be an under-utilization of transit resources.

Transit built form districts have minimum FAR allowances of 1.0 or more, meaning a new building’s floor area must equal at least the lot size area. With a typical minimum lot size of 5,000 sqft, a building on a Transit built form parcel will have to be 5,000 sqft, which is quite large for a 3-, 2-, or 1-unit dwelling in an urban area starved of housing. Ideally, Transit built form parcels will include an active use (non-residential) on the lower floor, with a significant amount of housing on the upper floors.

4. What other feedback do you have about Urban Neighborhood zoning?

A fair warning to readers: This is a very open-ended question, and so we’ve included several separate responses and lettered them to make navigation easier:

4A. Conditionally allow Urban Neighborhood districts to have small-scale commercial uses

  • 4A. Conditionally allow Urban Neighborhood districts to have small-scale commercial uses
  • 4B. Revise Built Form Interior FAR tables to encourage development of missing middle housing
  • 4C. Revise yard setbacks for taller buildings to be less restrictive

4A. Conditionally allow Urban Neighborhood districts to have small-scale commercial uses.
We’ve included a quote below from the city’s comprehensive plan (which already passed) regarding what Urban Neighborhoods should be:

“Urban Neighborhood is a predominantly residential area with a range of allowed building types. May include small-scale institutional and semi-public uses (for example, schools, community centers, religious institutions, public safety facilities, etc) scattered throughout like the Neighborhood Mixed Use category, commercial uses can continue serving their existing commercial function Commercial zoning is appropriate for these properties, while expansion of commercial uses and zoning into surrounding areas is not encouraged.”

Urban Neighborhoods” in Oct 2019 Comprehensive Plan, signed by Mayor Frey on Oct 30th, 2019

The important part here is that the city is saying new commercial uses in Urban Neighborhoods are “not encouraged”. The city has failed to allow any commercial uses in Urban Neighborhood districts (see the use table), and arbitrarily decided to interpret this as “…expansion of commercial uses and zoning into surrounding areas is explicitly prohibited”. Neighbors for More Neighbors disagrees with this viewpoint and believes the city should conditionally allow small-scale or desirable commercial uses in our Urban Neighborhoods. These uses may include, but are not limited to:

  • Restaurants
  • Coffee Shops
  • Grocery Stores
  • Bakeries
  • Services (dentist, hairdresser, etc.)

Conditionally allowing a use would mean that such a use in an Urban Neighborhood would need to be approved by the planning commission but would not need to have a hearing and approval at the city council to change the zoning map. This would allow the neighbors to decide for themselves, via input at the Planning Commission whether or not a particular use is desired in that neighborhood.

This would also vastly reduce the financial burden on small businesses who may be able to buy one of the 83% of the city’s parcels currently set aside for residential use (UN1, UN2, UN3) instead of forking over money to have a business in the 3-4.5% of parcels which are zoned commercially in the city in order to open a small business such as the kinds listed previously. 

It would also allow the built form Corridor 3-6 parcels that are getting zoned as UN3 to have the same kinds of mixed uses that are common along other corridors in the city. Allowing active commercial spaces along transit corridors (such as 46th St) has many benefits such as:

  • Increasing transit ridership/decreasing car usage
  • Creating local (walkable) destinations
  • Making business ownership more accessible to more people
  • Keeping money from neighborhoods within those neighborhoods

4B. The city needs to revisit its FAR allowances for 2, 3, and 4+ unit dwellings to incentivize development of missing middle housing in Urban Neighborhoods. This is already done in Interior 3 districts, and should be expanded to Interior 1 and 2. A table of the city’s proposed Floor Area Ratio (FAR) table is shown below, followed by an example of a table with a better gradient of building sizes:

Figure 2: Left two tables show current FAR tables in the draft code and what size building could be built on a typical 5600 sqft lot. Right two tables are N4MN’s suggested FAR allowances on the same lot size. Note how unrealistic it is to develop a triplex in Interior 1 and 2 zones on a typical lot, with an average unit size of only 930 square feet (a large 1-bedroom).

Having a better gradient of allowable building sizes encourages developers to make more housing throughout the city (because they can build larger buildings, and floor area is where the money is).

In general, differentiating between the three different Urban Neighborhood zones (UN1, UN2, UN3) is largely unnecessary due to the lack of difference in allowed uses. Urban neighborhood zoning accounts for a large portion of the city. It appears the intent of the new code is to regulate the intensity of dwellings throughout the city – something that is already accomplished by the built form regulations.

4C. Reduce setbacks and consider making them universal. 

Setbacks are in the draft zoning code in section 540. They vary drastically by zoning area and the ones for Urban Neighborhood corridors essentially prohibit buildings to be larger than 3 stories tall. For instance a Corridor 6, up to 6 story, 84’ building would have side yard step backs totaling 30’. A typical lot is 44’ wide. Meanwhile Commercial Mixed Use does not require setbacks at all unless they are within 25’ of another lower intensity area or it’s a single family home which then follows table 540-29. We recommend that the city just makes 540-29 universal to all lots except where setbacks are not needed. The setbacks in 540-29 are 15 ft front, 5 ft side/back and 8 ft corner side. That is more than sufficient for almost any building. Control building size with FAR instead.

5. Residential Mixed Use districts are established to primarily allow residential development. These districts also play an important part in increasing access to commercial uses and achieving the Complete Neighborhoods goal outlined in Minneapolis 2040 by allowing commercial activity. In most of Minneapolis, demand for retail is much higher than supply, indicating an opportunity to make retail more convenient for everyone and thereby reduce car trips and greenhouse gas emissions. The RM1 district is proposed to be applied to Urban Neighborhood property that fronts on a Goods and Services Corridor, allowing commercial activity as part of a multi-story mixed use building.

What types of commercial uses should be allowed in the RM1 Goods and Services District as part of a multi-story mixed use building with residential uses?

RM1 primary zones should include the following uses in addition to the uses already already designated:

  • Indoor recreation area (gyms, yoga, etc)
  • Offices (‘home’ office, lawyers offices, small businesses, etc)
  • Reception or Meeting Hall (more 3rd places)
  • Farmer’s Market
  • Grocery stores should be their own permitted use, with a 20,000 sqft allowance, instead of the current 5,000 sqft (see below)

Why Grocery Stores Matter:

In the draft’s current form, grocery stores fall under the “General Retail Sales and Services”. While this use is permitted in RM1 zones, they are limited to 5,000 sqft (it’s worth mentioning that RM2 and RM3 are limited to 10,000 sqft). To demonstrate how small this is, we’ve listed some Minneapolis grocery/retail store sizes below:

  • Trader Joes on Washington Ave: 10,700 sqft
  • Walgreens at 2650 Hennepin: 16,000 sqft
  • Cub at 4600 Snelling Ave: 40,000 sqft
  • ALDI at 3120 Penn Ave N: 13,000 sqft
  • The Quarry Target: 120,000 sqft
  • Kowalski’s at 5327 Lyndale Ave S: 21,000 sqft

All these grocery stores and retail stores exceed 5,000 square feet. Trader Joes is a grocery store that many would consider small, but sufficient to meet most needs, and is more than double the maximum size the city is currently proposing

For this reason, we recommend grocery stores become their own use category, and increase the allowed size across all RM zones to 20,000 ft­2 at a minimum, or do away with maximum sizes altogether for grocery stores.This change aligns with the city’s comprehensive plan policy number 63, Food Access which is increasingly important in certain parts of the city (such as where the ALDI at 3120 Penn Ave N is closing).

6. What other feedback do you have about Residential Mixed Use zoning?

There are several points we think could be changed in RM zones:

  • Residential Mixed Use zoning (RM1, RM2, RM3) is far too restrictive for grocery stores.
  • RM1 and RM2 should be combined (see explanation below)
  • RM districts should conditionally allow the following uses:
    • Tobacco shop
    • Liquor store, off-sale
    • Bar
    • Brewery or Distillery

Why should RM1 and RM2 be combined?

RM2 only has the following uses where RM1 does not:

  • General commercial recreation and assembly
  • Indoor recreation area
  • Outdoor recreation area
  • Lodging
  • Hotels (5-20 rooms)
  • Communication Exchange – Conditional
  • Heating and Cooling Facility – Conditional

We don’t believe any of these uses would be unfit for RM1 zones.

7. Following the recommendations in the Minneapolis 2040 future land use map, commercial zoning is proposed to increase by approximately 50% citywide. Encouraging and allowing for commercial activity is a key part of an overall strategy to reduce disparities between Black, Indigenous, People of Color and white residents in Minneapolis. While having zoning in place that allows for a certain use does not mean that use will be established, it is an essential step in allowing for needed economic development that achieves city goals.

What types of businesses and uses should be allowed in the new commercial mixed use zoning districts?

Bars and tobacco shops should be allowed in CM1, similar to the other CM districts. There are several existing bars in what will become CM1 districts. CM1 districts already will allow Breweries and distilleries.

Small scale glass, ceramics, and earthenware production should be conditionally allowed in CM zones, as long as they are compliant with a city noise and fume exhaust review. If one of these uses has harmful fumes, can be required to do high-exhaust like a laboratory (already permitted in CM2, CM3).

8. Which uses will best help to achieve the goal of Complete Neighborhoods while reducing car trips and greenhouse gas emissions?

The best way to reduce greenhouse gas emissions in a city is to reduce trips made by personal vehicles and incentivize more energy efficient dwellings by increasing FAR allowances for 2, 3, 4+ unit dwellings to incentivize more housing in the city instead of the suburbs.

Allowing commercial uses and destinations within Urban Neighborhoods reduces trips outside of those neighborhoods and means that people can walk to these destinations. People need food, child care, working spaces, medical clinics, and all the other necessities of daily life within a 15 minute walk of their home. In all weather and at all ability levels. Help us reduce emissions by making actual complete neighborhoods. 

Low density housing is the most energy intensive form of living due to each dwelling being exposed to the elements on all sides of the building, as well as a roof. Increasing floor area ratios for higher-density housing (2, 3, 4+ unit dwellings) in all interior zones would incentivize more energy efficient buildings and create much needed homes in Minneapolis neighborhoods.

9. What types of uses should not be broadly allowed in commercial districts?

Research, development and testing laboratories should be conditionally (C) allowed in all CM districts. Currently they are permitted (P) in CM2, CM3.

These facilities often have fume exhaust and animal testing facilities (vivariums), and there should be neighborhood impact studies (noise, sight of animal testing) done before these are permitted for construction. The HVAC involved in laboratories is intense, and therefore quite noisy. These uses should be sent to the planning commission to review noise, smell, and pollution impacts within neighborhoods.

10. What other feedback do you have about Commercial Mixed Use zoning?

The city has frequently stated that they will be expanding Commercial Use areas by 50%. However, Commercial uses are currently only 3-4% of the total parcels in the city while single family only zones, now UN1 and UN2, are 83%. Expanding to 5-6% is just not that impressive and is unlikely to lead to complete neighborhoods where everyone in the city can access daily needs without a car. 

It seems as though there is an unnecessary amount of zones. These could be consolidated into two or three Commercial Mixed Use zones instead of the current four. Having these additional zone types is confusing and makes the code even more inaccessible to the average person. One possible option is to combine CM3 and CM4 using the CM4 uses. 

Corridor Mixed use should be expanded along all bus routes if they decide not to change Urban Neighborhood 3 to allow commercial uses.

11. Downtown Minneapolis is a premier destination for companies, employees, and residents, and a center for regional commercial and entertainment options. Downtown offers an experience and a mix of goods and services that give it a competitive advantage over other areas in the region. Zoning has historically reflected and supported this reality by allowing a greater range of uses than anywhere else in the city.

Which uses should be considered that address the unique needs of the downtown core, downtown corridors, and downtown neighborhoods?

No comment on downtown zoning uses.

12. What other feedback do you have about Downtown zoning?

In the current draft, overnight shelters and supportive housing are only allowed Downtown. This means that people who need shelter have to travel downtown to have a safe place to sleep every night. We should allow more shelters and supporting housing in more places.

13. Low-income communities of color have been disproportionally impacted by polluting industries in Minneapolis and in cities around the country. Race more than class, has been the primary indicator for the placements of polluting industry for many years. Minneapolis 2040 calls for the elimination of disparities between BIPOC and white residents, one way of reaching that goal is to reduce the impact of polluting industries and in some cases no longer allow them within Minneapolis. Minneapolis 2040 suggests that we “identify and limit new heavy industrial uses that harm human health or the environment throughout the city.”

Which heavy impact (industrial) uses should no longer be allowed in the city?

No comment.

14. What other feedback do you have about Production zoning?

Production is the new name for Industrial zoning. And while the production uses have been de-intensified leading to an expectation of overall lower future pollution sources, they are still concentrated in the same places. Next to majority minority communities and apartment buildings. A common refrain in engineering is that “dilution is the solution to pollution” but we are seeing no changes in where production is located, and therefore the pollution and also proximity to jobs are still largely the same. 

15. The Land Use Rezoning Study covers a wide range of topics and issues. The free form field below is available for you to submit comments on items not highlighted elsewhere in this survey, such as the proposed Parks and Open Space zoning, changes to existing Overlay Districts, Proposed Zoning Maps, and structural changes to the code.

The city should revise the FAR allowances for multifamily homes (see answers to question 4).

The city should conditionally allow overnight shelters in places other than downtown.

The city should expand low-impact commercial into Urban Neighborhoods. The city can make these uses conditional to ensure unwanted uses don’t end up in neighborhoods.

The city needs to make grocery stores their own separate uses with larger use size allowances to decrease food scarcity in the city.

The city has not changed the zoning code since 1999. Committing to improving the code more frequently is helpful, but if this is our only change for the next 25 years it is not enough to tackle the challenges presented in the 21st century.

This post was written by multiple Neighbors for More Neighbors volunteers, and may not necessarily reflect the views of the entire organization. Please reach out to Zach Wajda at wajdazachary@gmail.com for specific questions.