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GETRO CITIES <br />Association of Metropolitan Municipalities <br />October 18, 2012 <br />Ms. Kelly Bamebey <br />Metropolitan Council <br />390 North Robert Street <br />Saint Paul, MN 55101 <br />Dear Ms. Barnebey: <br />Thank you for the opportunity to comment on the recommendations of the SAC work group <br />regarding the use of SAC credits. <br />Metro Cities approached MCES this suminer to request a discussion of SAC policy to determine <br />whether there might be some allowance to use SAC credits city wide. MCES agreed, and a work <br />group was established to review the policy and make recommendations. 1 participated as a co- <br />chair of this group, and several city officials fxom across the metro region served on the group. <br />Metro Cities would like to thank MCES staff and Met Council members Wendy Wulff and Gary <br />Van Ry11 for their work with us and for promoting an informative and thorough process around <br />the various policy considerations associated with recommending changes for SAC credits. <br />Metro Cities' policies support flexibility to allow SAC credits to be used on a city wide basis. <br />Although we worked with MCES on the no -net -credit policy adopted in 2010, this policy has <br />since raised numerous concerns by city officials with respect to redevelopment challenges and <br />lack of credit flexibility, and the impacts of SAC credit restrictions on business growth and <br />expansion, particularly in a recessive economy. <br />While our policies support additional flexibility around credits, Metro Cities does want to ensure <br />that any policy changes will not compromise equity for users, will not make the program more <br />complex and will not significantly increase SAC rates, <br />Metro Cities support s the recommendations outlined in the Final Report of the work group, <br />which had unanimous consent by group participants. These changes would allow for SAC <br />credits to be used city wide, at the city's option, with SAC paid as sufficient evidence to generate <br />credits (with exceptions for non -conforming uses and grand -parented properties). Metro Cities <br />further supports the recommendation that allows for minor SAC credit transfers and limiting <br />community reviews to three years. <br />(OVER) <br />145 University Ave W s St. Paul, MN 55103-2044 • Phone (651) 215-4000 . Fax (651) 281-1299 • www.MetroCitiesMN.org <br />