All the claimed benefits in the Developer and Investor’s Application Narrative would equally be provided by a smaller structure, with transitions to the lower density surrounding areas, with less negative impact on the existing neighborhood.  The narrative to justify the rezoning, the CUP and the variance requests centers on three main areas: Claimed Benefits, Compliance with the 2040 Comprehensive Plan for St. Paul and Invalid Allegations & Comparisons.

Claimed Benefits

None of the narrative accompanying this proposal mandates a five-story structure that utilizes 84% of the property with a design that does not integrate with the current nature of the neighborhood.  The claimed benefits are:

• Add residential density
• Create a more inviting streetscape (activate)
• Support existing and new commercial uses on Grand Avenue
• Support mixed-use development

A smaller structure, with transitions to the lower density surrounding areas, would provide the same benefits with less negative impact on the existing neighborhood.  The difference would be the amount of profit cleared by the owner.  Bigger is not necessarily better.

Compliance with the 2040 Comprehensive Plan for St. Paul

All the references to Goals and Policies in of the 2040 Comprehensive Plan for St. Paul in the narrative can be equally fulfilled with a smaller structure, with transitions to the lower density surrounding areas, with less negative impact on the existing neighborhood.  There are three policy references that need to be challenged.

Policy LU-1. Encourage transit-supportive density and direct the majority of growth to areas with the highest existing or planned transit capacity.

• This policy clearly states that the “majority of growth” should be directed to area of “the highest existing or planned transit capacity.” Grand Avenue is a two-lane city road with one bus line in contrast with other high transit capacity corridors that are four lanes wide and are county roads. Grand Avenue’s transit capacity does not rank among the highest existing nor are there plans to make it one of the highest. 
• Why is this proposed density higher than projects on University Avenue which is a four-lane road with buses and rail transit options?
• Will the planners “direct” appropriate growth to Grand Avenue?

Policy LU-29. Ensure that building massing, height, scale and design transition to those permitted in adjoining districts.

• The proposed project’s mass, height, scale and design DO NOT TRANSITION to the adjoining RT2 and RM2 zones.
• The narrative claims that “appropriate transitions” will be provided. Who is making the decision on the appropriateness?  Are we going to allow the developers and investors whose primary goal is profitability decide what is appropriate for our neighborhood?
• Repeated feedback from the neighborhood objecting to the massiveness and height of this proposal cannot be written off by simply declaring that they are designing “appropriate transitions.” The appropriateness measures used by developers and investors are only driven by profit margins and do not protect the character of the neighborhood.

Policy H-47. Encourage high-quality urban design for residential development that is sensitive to context, but also allows for innovation and consideration of market needs.

• This proposal, using a generic design that the developers have used repeatedly all across the metro, is not sensitive to the context of the Summit/Grand neighborhood.
• The narrative claims that the building design will be “contemporary with nods to its historic context and surrounding neighborhood character.” How can this reused design be sensitive to context in all these various settings?  This design will degrade our community charm.

Invalid Allegations & Comparisons

The narrative implies that there has not been any new development within EGOD since it was enacted.  Below is a list of recent developments along EGOD, which invalidates their allegation.

• New construction and reinvestment in EGOD
  • Union on Grand condominiums – new construction – 2018-2019
  • Family Means, located in two business-in-houses (Zoned BC) between Dunlap and Lexington – reinvestment – 2021
  • Red Balloon – new local ownership 2019, has been improved + creatively managed the pandemic with local delivery
  • Iron Ranger has expanded – 2020
  • Coconut Thai – new construction – 2020-2021
  • Planned Avivage Massage expansion – 2021

The one comparison that the narrative uses to justify their request to build a 60 foot, five-story building is the Grand Place condominium building at 745 Grand Avenue.  Below is a table making comparisons between the two structures.  Grand Place was built prior to EGOD yet even so chose greater setbacks from adjacent properties than what is being proposed for 695 Grand.  The 695 building will house 4 commercial (restaurants/ retail) places, whereas Grand Place is a residential building.  Thus 695 will generate extra noise/ extra traffic, delivery trucks, extra trash pickups, extra visitors, cars etc.  This is an invalid comparison.

This rezoning request amounts to “spot zoning” of the type forbidden by federal regulation(s) deferred to in the applicable Minnesota Statute.  It is not being undertaken as part of comprehensive zoning and would be done primarily to allow this developer to build a five-story building in this location.  This amounts to an unjustified exception to the existing zoning codes with the primary benefit to the property owner and investors and it differs significantly from the zoning of other property in the immediate area.