Dr. William Tozer: Commentary on the 2040 Draft Comprehensive Plan for Minneapolis


The broad goals of the 2040 Draft Comprehensive Plan for Minneapolis are laudable and fairly unassailable to a fair-minded person. However, it is questionable how many of those goals can be achieved through city planning rather than other policy mechanisms—and I am particularly concerned that the proposed Land Use and Built Form plans will not only not address these goals, but could in fact be counterproductive. Given that so many of the goals of the 2040 Plan are economic, it seems very pressing that economists are engaged to assess its likely effects—but Heather Worthington of the City of Minneapolis has reported at community events that no such analysis has yet been conducted.

Time Frames and Goals

The Land Use and Built Form proposals put forward in the draft 2040 Plan are curiously both radical in some respects and unambitious in others—potentially endangering the very growth that is the assumption underpinning the entire initiative, while simultaneously not addressing the enormous problems caused by the last instance of radical planning in Minneapolis, the twentieth century introduction of freeways. While I am aware that the 2040 Plan sets out maximum building densities, it seems clear that a full build-out of the limits it sets would provide housing quantities vastly in excess of the predicted growth for Minneapolis over the time frame of this plan. Given this, and the fact that there will be another Comprehensive Plan sent to the Metropolitan Council in ten years time, it seems clear that the proposals in the 2040 Plan are over-zealous. As the name of the 2040 Plan suggests, it looks slightly beyond the end of the plan that will be prepared in another ten years time, but I would argue that even for that longer time horizon the potential densities it would allow are out of proportion with likely growth, and that other infrastructure (transport, parks, schools etc.) would be unlikely to be able to keep pace with this. This should not be confused with being ambitious—it is too risky to leave it to private interests (developers, house builders etc.) to determine how much of the allowable density is realized and in what time frame. If the Land Use and Built Form proposals in this draft of the 2040 Plan are longer-term goals, there needs to be much more serious consideration given to what are realistic and desirable goals for the ten year period that this Comprehensive Plan submission to the Metropolitan council covers. I doubt that under scrutiny a full build-out of the draft 2040 proposals would prove desirable in the next Comprehensive Plan, let alone in the one currently under consideration.

Corridors, Zones and Nodes

The most radical departure of the 2040 Plan from the preceding Minneapolis Plan, is a significant expansion in the use of “corridors” of development (or ribbons as they are known more broadly in urban geography terminology), which previously were used very sparingly by comparison to zones and nodes. Given the size and distribution of these corridors and the fact they could allow much more development than is needed with any immediacy, it is likely that the resulting new housing would be highly sporadic. Construction would occur where lots become available and are most profitable for developers, but it seems highly optimistic to assume that they would be sufficiently concentrated or connected to make high-frequency transit viable as a result of their construction. This assumption underpins most of the 2040 Plan, which relies upon concentrating housing to make make mass transit viable, to in turn improve access to employment. Over the ten-year span of the plan currently under consideration, it would seem much more viable to concentrate development on nodes that are strategically positioned to be connected by corridors or ribbons of development in future Comprehensive Plans and zoning changes. Most importantly, however, these new nodes should be zoned with the view to how they might function autonomously if commercial development does not follow the pattern that the zoning aims to encourage.

Historic Preservation, Land Use and Built Form

The sporadic development that I fear would result from the current draft of the 2040 Land Use and Built Form proposals is also likely to be extremely incongruous to existing patterns of housing, and risks causing a decline in the uniqueness and quality of neighborhoods, which could in turn risk stagnation or declines in population. The historic preservation sections of the draft 2040 Plan recognize the importance of built form in constructing residents’ mental image of their neighborhood and city, but the Land Use and Built Form proposals overlook the fact that much of this identity resides in the overall quality of building stock, rather than individually significant buildings that might qualify for listing on the Historic Register. The perspective visualizations of the various Corridor, Interior, Core and Production zones (pages 63–68) are not surprisingly shocking to many residents as in many instances they bear no resemblance to the existing built environment on the streets that are identified as belonging to each zone. Consequently, the 2040 Land Use and Built Form proposals appear to propose a scorched earth approach to existing building stock, even in historic neighborhoods. If this is not the intention of the 2040 Plan this needs to be corrected and clarified with the utmost urgency.

Visualizations an Worst-case scenarios

In addressing the above issue, the perspective visualizations need to be developed to show potential worst-case scenarios allowed by the proposed Land Use and Built Form proposals. Putting aside the fact that the visualizations included in the draft 2040 Plan imply the complete demolition of all existing buildings, they do show a very idealized situation where all lots have been developed in fairly consistent and sympathetic manner to one another. In its current draft form, the 2040 Plan would appear to allow (in Corridor 4) a four-story apartment building with no set-back to be constructed alongside an existing single-story house with a 25-ft setback from the sidewalk, rendering the existing home’s front yard heavily shaded and overlooked. The current visualizations do not show whether such an apartment building would have a significant setback from the rear boundary, but the same problems could also be true of the rear yard of an existing neighboring house. The various Corridors and Interior designations also do not specify how use will controlled and the visualizations show commerce in what are currently entirely residential neighborhoods. The final version of the 2040 Plan needs to be specific about how use will be controlled in each zone. If it is not, the above worst-case scenario needs to be reimagined with this added incongruity of conflicting uses. I am confident that these worst-case scenario visualizations would reveal the folly of allowing development over such large corridors, rather than in nodes with the potential to be connected in the future.

Attenuating the Negative Side-effects of Development

The only apparent mechanism in the draft 2040 Plan for attenuating the negative effects of the proposed radical changes in built form on existing neighbors is a tapering of allowable building height. Corridors 4 and 6, which allow for four-story and six-story buildings respectively, are fringed by bands of Interior 3 designation, which allows development of up to 3 stories. Inherent in this strategy is the understanding that such a tapering of building height is critical for maintaining amenity to smaller neighboring buildings, and yet the visualizations do not recognize that exactly this problem will exist within each the corridor zones themselves—new four and six-story buildings will be allowed to abut existing housing and other buildings as small as a single story. The other obvious problem with this tapering is that it is a blunt instrument—the same tapering (the Interior 3 bands) abuts both Interior 4 and 6 areas. The latter could be addressed by introducing an Interior 5 category, but the former problem—massive inconsistencies in building height within the Corridor and Interior zones—could only be addressed by a more subtle mechanism, such as limiting new building heights to no more than one story higher than any existing neighboring building, and new footprints to no more than 5 ft further forward or back than the least extensive neighboring property.

Respecting Variations in the Grain of Existing Neighborhoods

The proposed Corridor 4 and 6 designations are very blunt instruments given the large variation in street types to which they are applied. For example, Hennepin Avenue S, Lyndale Avenue S, and W 50th St are all significantly wider than Bryant Ave S, and yet all four have the same Corridor 4 designation in the the 2040 Plan. Streets such as W 21st Avenue in Kenwood are significantly narrower again than even Bryant Ave S, and yet are also remarkably assigned a Corridor 4 designation. The Corridor 4 and 6 designations seem to be based entirely upon their designation as high-frequency transit routes. No regard seems to have been given to street width, which is a critical factor in determining appropriate building height. The building height to street width ratio on W 21st Street would not only be very different to wider streets like Lyndale Ave S with the same Corridor 4 designation, but the ratio would be such that it would create an incongruously urban degree of enclosure, resulting in an uncomfortable pedestrian environment and, particularly because of its east-west orientation, poor levels of sunlight to the street and the buildings to the northern side. Wind studies might well also reveal a wind tunnel effect result from such a narrow and tall built environment, which the draft 2040 Plan sets out to avoid in principle. Many of the same problems would arise with the proposed four-story buildings on the section of W Franklin Avenue that passes along the southern edge of Kenwood Park, and on the affected portion of Penn Ave S—the height disparity between the new four-story buildings on the western side, and the historic school building on the eastern side would be exacerbated by a change in the natural terrain between the two. The Lowry Hill portion of W Franklin Avenue proposed to become part of this corridor is wider than W 21st Street, but only comparable to Bryant Ave S, both of which would be much more negatively affected by four-story building heights than wider streets like Lyndale Ave S.

High-frequency Transit Routes as Built Form Corridors

While street width and existing building stock should surely be factors, transit frequency alone seems to have determined the designation of Corridors 4 and 6 in the draft 2040 Plan, even the application of this seems inconsistent. Most of these corridors are well established light rail or bus routes, but some—like the one that traverses Lowry Hill and Kenwood via Franklin Avenue S, Penn Avenue S and W 21st Street—do not currently exist. Using this particular route as a case study, it is important to note that it terminates at the proposed W 21st Street-Kenilworth Trail station for the Southwest Light Rail extension project. The designation of this as a high-frequency transit corridor, and consequently its Corridor 4 designation for Land Use and Built Form development, should surely be conditional on this project and station being completed. Even if the project proceeds, and proceeds with the W 21st Street station, consideration should be given to the fact that this station was presented to the local neighborhood as “a neighborhood walk-up station” and it was stated that “future development is not envisioned around this station.” To consequently use this station as the justification for the creation of a high-frequency transit corridor and continuous four-story apartment development would seem to make a mockery of the undertakings that were made during consultation process on the light-rail project (see link).

Case Study—the W Franklin Ave S-Penn Ave S-W 21st Corridor

Only part of this particular proposed Corridor 4 route currently has a bus route, the number 25, which only runs during rush hours, and apparently has low rider numbers even at those times. While the frequency and ridership of this route might increase significantly if the light rail extension and W 21st station proceed in order to bring passengers to and from the station, it seems implausible that riders would bus this route from further afield than the western side of Lake of the Isles, beyond which they would surely be more likely to go east to Hennepin Avenue where they can connect with a number of different high frequency bus routes to travel north or south. In reality, it seems likely that most Kenwood residents would walk to a W 21st Street light rail station, and most Lowry Hill residents would walk to Hennepin Avenue to catch a bus. Furthermore, the draft 2040 Plan’s proposed high-frequency transit corridor for W Franklin Ave S-Penn Ave S-W 21st varies significantly from the current route, which travels from Hennepin down Douglas Ave instead of W Franklin Avenue, presumably because of the difficultly of buses navigating the steep hill where W Franklin Avenue meets Kenwood Park and Lake of the Isles; particularly challenging for vehicle traffic in the winter. The current bus route proceeds along Douglas Ave to the northern end of Kenwood Park, where the amenity of the park space is significantly lower than at the southern end—where bus traffic on W Franklin Ave would bisect the soccer fields of Kenwood Park and the walking and cycling trails on Lake of the Isles Parkway. For these reasons it would seem more prudent for the transit corridor to remain on the existing bus route and for rider numbers to be monitored after the opening of a W 21st Street light rail station before the frequency of the bus route is increased let alone the streets rezoned for four-story development.

Density and height of Development

It should be noted that in the above example, Kenwood, like many other parts of the City of Minneapolis does not currently have building stock that maximizes the existing zoning restrictions, suggesting that it is highly optimistic to believe that loosening height and density restrictions still further would result in more building. If, however, the City of Minneapolis wants to introduce more density into neighborhoods like Kenwood, it would seem sensible to instead explore relaxing rules around building multi-unit housing within the existing height and setback restrictions for single-family dwellings—many lots are large and could accommodate this. If the City is particularly wedded to medium to high-rise development, I would suggest that this type of development should be positioned where it can significantly improve built environment rather than requiring the demolition of well-functioning existing housing stock. In the Kenwood neighborhood, the portion of the Kenwood Parkway adjacent to the 394 freeway would seem an obvious location. The introduction of this freeway and the very tall wall that encloses it have greatly diminished the suitability of this streetscape for the low-rise, single-family homes that currently occupy this area. Well-designed apartment buildings here would could take advantage of views over the freeway wall, while lower-level units could open to the gardens and courtyard to the hillside, sheltered from the sound of the freeway by the building mass. I would suggest this is an example of the type of locations where the final version of the 2040 Plan should look to increase density and building height elsewhere in the city—where it will not be to the detriment of the existing built environment, and can in fact improve a pressing problem for the City of Minneapolis. The entire southern edge of the I-94 freeway, through the Stevens Square, Ventura Village and Seward neighborhoods would seem to present a similar opportunity. The draft 2040 Plan currently designates these areas predominantly as Interior 3, a building mass that will not be able to stand up to the visual and aural environment of being adjacent to the freeway. Loft apartments in the North Loop are a local example that highly desirable housing can be created adjacent to freeways, and this model could be significantly improved upon.

The Limitations of Public Consultation

I am concerned at the degree of emphasis that has been placed on public consultation in the drafting of the 2040 plan, seemingly at the expense of targeted expert consultation, particularly from urban designers and planners in other cities regionally, nationally and internationally—where many of the types of streetscapes the 2040 Plan aspires to create already exist and have been introduced or maintained successfully. While it is important to engage the public, this process seems to have been lopsided towards prolonged consultation in the most general of terms, and then a very short period of consultation on what the City of Minneapolis is actually proposing. The most concerning aspect of the reliance on public consultation is that the unevenness of residents’ opportunities across the city—which the 2040 Plan aims to address—were very likely reflected in inequitable opportunities to contribute feedback, further entrenching disparities. In this vein, my comments on my own neighborhood and the parts of the city I regularly inhabit are couched in terms that I hope will make it possible for them to be extrapolated to rethink other areas of the Land Use and Built Form proposals.

Addressing the Freeway Problem

It is disappointing that the draft 2040 Plan is not more ambitious in a number of ways. Most importantly, it is widely recognized that the encircling of the downtown by freeways has caused a very harmful disconnection of the surrounding neighborhoods—both physically and in terms of the mental image of the city. However, the draft 2040 Plan does not seem to directly address this—in fact, the proposals with only a couple of exceptions allow significantly higher density development on one side of the encircling freeways to the other, heightening the sense of separation of the downtown from the neighborhoods on the other side of the freeways. Evening out building densities and heights from one side of the freeway to the other would seem crucial to diminishing the perception of the freeways as breaks in the city fabric. While “lids” over portions of the freeway system have generally been considered prohibitively expensive, the 2040 Plan could at least make strategic areas available for private development to do this—obviously dependent upon mechanisms for public-private funding and partnership. The most pressing situation for this approach is the reconnection of the Minneapolis Sculpture Garden with Loring Park. Conversely, the ground space at the convergence of Hennepin and Lyndale Avenues just to the south is salvageable as urban streetscape—the current treatment of this as green space is ineffective and worsens rather than improves the disconnection of these streets from the Walker and Loring Park. A more modest version of the lid concept would be to allow street-like bridges edged with some building to the streets that pass over the I-94 freeway on the southern edge of the downtown—Nicollet Avenue being perhaps the best candidate to develop first.

Parks and Urban Outdoor Space

The recent redevelopments of Nicollet Mall and the Commons are assets to Minneapolis, but these projects need to be seen as the first step in creating more civic space in the city, particularly in the downtown area but elsewhere also. The park system of the Minneapolis is enviable, but the vision of what constitutes a park could do well to be broadened from being only empty green space. It is questionable whether the current model is actually particularly natural as it entails a lot of mown lawn, while the city could benefit from at least some of its park space being more urbane, particularly in the downtown and some central neighborhoods. The new Commons park downtown is a vibrant urban gathering space when food trucks line its edge, but otherwise lacks the immediate adjacency of semi-public functions like restaurants and cafes that is critical to activate it. While some of these things are nearby, the park is mostly ringed by vehicular traffic. The dominance of lawn and the informality of the planting would be more appropriate in a suburban context, and more urban approaches would be advisable for future similar developments. What the downtown area could really benefit from is more public outdoor gathering space in the form of squares, plazas and piazzas, and the draft 2040 Plan does not seem to identify any such spaces. While the top edge of Bde Maka Ska (formerly Lake Calhoun) is technically park land, the amenity of this space is very poor due to the high-frequency vehicle traffic on W Lake Street. This area would seem well-suited to a first attempt at a more urban approach to Minneapolis lake frontage—incorporating substantial restaurant and cafe development that can mediate between the lake frontage and the road traffic. Lake Street currently terminates in a small pier ostensibly for the use of boaters; a much larger public pier and boardwalk would seem a more appropriate and inclusive way for a large number of Minneapolitans to be able to enjoy this city lake.

Integrating Historic Preservation into Land Use and Built Form Policies

The historic preservation elements of the draft 2040 Plan appear need to be integrated into the Land Use and Built Form documents to ensure that these issues are actually addressed in patterns of development. These protections should be much broader than spot listing of individual buildings—for example, the proposed building height limits for Loring Park seem likely to lead to the widespread demolition of the historic brick, four-story apartment buildings that collectively define the charming character of this urban neighborhood, despite none being individually significant. Similarly, Lowry Hill is an example of a neighborhood with an historic character critical to the mental image Minneapolis—the 2040 Plan’s proposal to allow a high-frequency corridor of transit and four-story development through neighborhoods of this type would be catastrophic. Different Minneapolis neighborhoods have distinct characters and the 2040 Plan should ensure this is preserved, while in its current form it risks creating homogeneity of the built environment.

Summary of Recommendations

In summary, I would argue that the Land Use and Built Form components of the Draft 2040 Comprehensive Plan for Minneapolis require significant and substantial revision before they should be approved. Even if widespread corridor development is a longer-term goal, the current plan under consideration should concentrate on fewer, already-burgeoning corridors such as Hennepin, Lyndale, Nicollet and Central Avenues—rather than risk spreading building investment too thinly, and consequently achieving very little positive change to the urban space of any of them. The final version of the 2040 Plan should dispense with the proposals for new corridors in favor of strategic nodal development to facilitate possible future corridors without causing destructive changes in the immediate ten-year time frame. The 2040 Plan also needs to be revised to offer finer-grained restrictions on height, density and setbacks that ensure development is sympathetic to existing buildings and residents in distinctly different existing neighborhoods—and to allow for and encourage more organic growth and change. Finally, I would propose that the new Comprehensive Plan for Minneapolis needs to include proposals to improve access to parks and urban outdoor space, including leveraging the unique characteristics of the Minneaopolis’s lake setting. In conclusion I would suggest that while the name of the Comprehensive Plan currently under review—Minneapolis 2040—is intended to show consideration of a longer time horizon than the immediate ten-year remit, it has been over-zealous in doing so and has looked much further ahead—to the detriment of the current situation and needs. The final version of this Comprehensive Plan for Minneapolis needs to focus more keenly on the time frame in hand, albeit with an eye on much longer term goals.


William Tozer is an award-winning architect.  You can read about his work at:


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