Roles, responsibilities, and implementation

This section describes the key areas where this 2050 Housing Policy Plan refines and builds upon existing Met Council policies and roles. It provides an overview of the available implementation tools for achieving the policies and actions in the first three sections of the plan, including how we will:

• Review comprehensive plans for meeting statutory housing requirements and for consistency with regional housing policy on the following areas:
  • Housing Needs (Future and Current)
  • Land Guided for Affordable Housing
  • Housing Implementation Plan
• Support housing development across the region
• Expand our role in providing technical assistance for housing
• Convene and partner to elevate dialogue around key regional housing issues 

Specific local comprehensive plan requirements, along with tools, resources, and fact sheets for housing, are contained in the Met Council’s Local Planning Handbook and will be updated following adoption of Imagine 2050. 

Housing requirements for local comprehensive plans 

Cities, townships, and counties in the seven-county region prepare local comprehensive plans every 10 years, as required by the Metropolitan Land Planning Act. These plans must include a housing element and a Housing Implementation Plan. Local governments will begin this decade’s round of local comprehensive plan updates following Met Council adoption of Imagine 2050 and the system and policy plans, including this Housing Policy Plan. Under the Metropolitan Land Planning Act, local comprehensive plans must include a housing element that: 

• Contains standards, plans, and programs for providing adequate housing opportunities to meet existing local and regional housing needs;
• Acknowledges the city or township’s share of the region’s need for low- and moderate-income housing (the Future Need); and promotes the availability of land for the development of low- and moderate-income housing; and
• Includes an implementation section identifying the public programs, fiscal devices, official controls, and specific actions the city or township will use to address their existing and projected needs (Minn. Stat. § 473.859, subds. 2 and 4) 

The Met Council reviews updated local comprehensive plans based on the requirements of the Metropolitan Land Planning Act and the regional development guide (Imagine 2050 and the associated system and policy plans). Cities and townships without forecasted sewer-serviced growth are still required to include a housing element in their plan and a Housing Implementation Plan but are exempt from the requirements that depend on forecasted sewer-serviced growth such as Future Need and Land Guided for Affordable Housing. The following subsections are a high-level overview of the housing requirements for local comprehensive plans. More information will be supplied to cities and townships in the forthcoming Local Planning Handbook. 

Future and current affordable housing need 

Future Affordable Housing Need

Under the Metropolitan Land Planning Act, local comprehensive plans must include: 

“…a housing implementation program, including official controls to implement the housing element of the land use plan, which will provide sufficient existing and new housing to meet the local unit’s share of the metropolitan area need for low- and moderate-income housing.” (Minn. Stat. § 473.859, subd. 4) 

To determine the need for affordable housing for each city and township with sewer-serviced forecasted growth, the Met Council calculates a “Future Affordable Housing Need” (“Future Need”) for each applicable jurisdiction (previously named the “Allocation of Affordable Housing Need,” or “Need”). The Future Affordable Housing Need serves as an objective prediction of the number of added low-income households through the decade from 2031-2040, for which the region will need to plan affordable housing. In that decade, the Met Council forecasts that our region will add 39,700 low-income households that will need affordable housing. The Future Need calculation measures future affordability demand and does not incorporate existing unmet demand for affordable housing.

The Future Need calculation

The 2031-2040 Future Need calculation will focus on low-income households who will need housing affordable at 60% AMI or less, including specific bands of affordability at 30% AMI or less and 31%-50% AMI.¹⁰¹ This is intended to ensure that cities and townships are prioritizing the creation of deeply affordable housing. The lower overall Future Need numbers, compared to the prior decade, will enable cities and townships to take a more focused approach to meeting their Future Affordable Housing Need (See more about how the Future Affordable Housing Need is calculated in Appendix C). To continue to highlight the need for different affordable housing types such as townhomes, ownership options, and larger units, this Met Council plan will also require comprehensive plans to address housing opportunities that fall within the 60-115% AMI range.  

Local governments with forecasted sewer-serviced growth are responsible for guiding adequate land at the minimum densities necessary to allow affordable housing development to meet their allocation of the region’s Future Need, as detailed in the Land Guided for Affordable Housing section, below. The availability of land that can support affordable housing gives developers a variety of geographic choices to consider for affordable housing development. Building affordable housing across the region gives low-income households more viable options as to where they can afford to live. 

Current Affordable Housing Need

Ensuring the region is planning for enough additional housing units to meet Future Need only meets a portion of the total affordable housing need in the region. It is also necessary for cities and townships to address the current gaps in demand for affordable housing.  

Under the Metropolitan Land Planning Act, local comprehensive plans must include a housing element that addresses existing/current, not just future, housing needs in the community. This current need must include the needs for increased affordable housing opportunities for the people who already reside in the city or township, as well as current regional housing needs. The Met Council will provide an Existing Housing Assessment that will serve as the starting point for cities and townships to determine their current local and regional housing needs. Housing elements of local comprehensive plans will need to analyze their Existing Housing Assessments through the lens of local knowledge and priorities to identify clear, specific housing needs to be addressed in the Housing Implementation Plan. Local comprehensive plans must, at a minimum, contain an assessment of the following:

Current Local Needs:

• • Share of existing affordable housing within the following bands of affordability and tenures:
    • Rental: Less than 30% AMI, 31-50% AMI, 51-60% AMI, 60% AMI or greater
    • Ownership and co-operative: 50% or less AMI, 51-60% AMI, 61-80% AMI, 80%-115% AMI, 115% or higher AMI
  • Share of rental and ownership housing in overall housing stock
  • Split of detached, manufactured homes, 2- to 4-unit multifamily, and larger multifamily housing
  • Number of units of publicly subsidized housing
  • Number of existing households at incomes at or below 80% AMI that are experiencing housing cost-burden
  • Land that is staged to be developed/redeveloped in each planning decade 

Current Regional Needs:

• • Providing affordable housing opportunities that are accessible to households of varying abilities
  • Need for the maintenance and preservation of unsubsidized affordable housing
  • Households who are or are at risk of losing housing

To aid in planning for additional demographic-driven affordable housing types, the Council will also require local governments to consider the need for the following subcategories:  

• The need for affordable ownership opportunities based on “homeownership-ready” households at 80% AMI or below 
• The need for affordable housing units that are age-restricted or offer supportive services for older people

Local governments will then be required to incorporate within their comprehensive plans potential tools that they will continue or seek to use throughout the decade to meet these needs. (For more information see the section below titled Housing Implementation Plan).

Land Guided for Affordable Housing

Allocating a Future Affordable Housing Need within the three bands of affordability enables local governments to focus on the kinds of affordable housing that are most needed in their community. This Future Need must be considered when guiding future land uses in local comprehensive plans. The Metropolitan Land Planning Act (Minn. Stat. § 473.858, subd. 2(c)) states that housing elements contain “land use planning to promote the availability of land for the development of low- and moderate-income housing.” 

Land availability is measured in comprehensive plans by having enough land available for development or redevelopment guided at high enough densities to support the creation of affordable housing sufficient to meet a city or township’s Future Need. Higher density promotes the availability of land for affordable housing in several ways: 

• Increased density often correlates with reduced costs of developing new housing by reducing per unit cost of land and fixed infrastructure. With limited resources for developing affordable housing, any mechanisms that reduce development costs can help promote affordable housing development.
• Increased density creates more housing units overall. Increasing the number of units on the market can still promote the availability of affordable housing by increasing the supply of all housing units.
• Sites with higher density signal to affordable housing developers where communities are more likely to support affordable housing proposals.  

For context, of all multifamily units (greater than four units per property) built between 2014 and 2019 that were affordable at 60% AMI or less, the average project density was more than 56 units per acre.¹⁰² Flexibility is an important part of housing elements, so the Met Council is proposing much lower minimum densities than this, as described below. However, we strongly encourage local governments to consider densities higher than these minimums in order to more realistically represent the density at which affordable housing is developed. We will provide technical resources to local governments to illustrate what different densities can look like in different kinds of city and township types and contexts.

Local governments who have been allocated a Future Need should guide an adequate supply of land at the following appropriate minimum densities to meet their Future Affordable Housing Need: 

• Option 1: Guide sufficient land at a minimum density of 10 units/acre to meet the city or township’s total Future Need.
• Option 2: Guide sufficient land at a minimum density of 12 units/acre to meet the Future Need for 30% AMI or less and a minimum density of 8 units per acre to meet the need at 31-60% AMI (the two higher bands of affordability). 

These two options allow for flexibility in how a city or township guides land to meet the statutory requirements within the range of community characteristics in the region. Only enough land sufficient to address the Future Need is required to be guided. Additionally, if a city or township chooses Option 2 and has a demonstrated history of creating affordable units¹⁰³ at densities lower than eight units per acre, they may guide land at lower minimum densities (as low as 4-8 units/acre) when promoting land availability at the 51-60% band of affordability.  

Cities and townships that do not guide an adequate supply of land at appropriate densities to meet their Future Affordable Housing Need will be considered inconsistent with Met Council policy and therefore will not be eligible to participate in or receive funding from the Livable Communities Act grant programs. 

Credit for Land Guided for Affordable Housing

Guiding land use is only part of the solution for creating affordable housing development opportunities. To incentivize the adoption of policy that facilitates the creation of new affordable housing units, local governments will have the opportunity to apply a credit towards their overall Future Need number and reduce their Land Guided for Affordable Housing obligation. This credit will apply to a local governments’ total Future Need number, which would reduce the number of eligible acres a city or township would need to guide to meet the statutory requirements of their housing element. The Met Council will provide technical resources on what qualifying policies will count for this credit. Examples could include an inclusionary housing policy or collaboration with a community land trust.

A maximum of 15% of the local government’s Future Need will be eligible for credit. 

Housing Implementation Plan

Local governments have a variety of tools at their discretion to encourage, incentivize, and even directly create affordable housing opportunities; guiding land at higher densities alone is insufficient to meet the existing and future needs of affordable housing.  

The Housing Implementation Plan portion of a local comprehensive plan must identify a city or township’s “public programs, fiscal devices and other specific actions to be undertaken in stated sequence” (Minn. Stat. § 473.859, subd. 4) to meet existing housing needs. It must clearly and directly link which tools will be used and in what circumstances, to explicitly address the housing needs previously identified. A successful Housing Implementation Plan will identify tools that the local government is already using, tools the local government will consider, and which tools the local government will commit to using to meet current and future local and regional housing needs.  

This round of comprehensive plan updates will require that local governments identify three specific housing needs that represent the greatest needs of their community and identify the tools they will commit to using to address these three needs throughout the planning decade. Complete Housing Implementation Plans do not have to commit to using every available tool to meet all their housing needs but must identify specific actions and consider all reasonable resources.

As with Thrive MSP 2040, the Met Council will continue to provide technical assistance to help local governments identify and direct their resources. The Met Council will provide a list of eligible tools that can fulfill these requirements by community designation to best represent the different abilities and conditions of cities and townships in addressing housing issues. The Local Planning Handbook will also be provided as a resource. 

We will not require that a city or township adopt any particular tools, with the exception of the requirement to address the top three housing needs identified by the local government. The city or township must describe which tools it will implement and describe the sequence of or conditions for their implementation.  

Cities and townships will be asked to complete a Housing Action Plan annually. The Housing Action Plan is a series of narrative questions that ask how a city or township is progressing towards meeting their goals identified in their comprehensive plan. These questions are distributed through the annual Housing Policy and Production Survey administered by Met Council housing staff.¹⁰⁴ The Housing Action Plan contains very open-ended questions that ask cities and townships to report on efforts made at the local level towards meeting their city or township’s housing goals. This requirement does not mean that cities and townships must have made specific progress in meeting their housing goals. A city or township’s failure to report on progress towards their housing goals through this existing statutory requirement could result in barriers to a city or township’s ability to receive funding from Livable Communities Act programs (Minn. Stat. 473.254, Subd. 2).

Local comprehensive plans should be clear, transparent policy documents that provide road maps to address housing needs for planners, local leaders, developers, and residents alike, and allow city and townships to hold themselves accountable for using all available tools and resources to meet local, regional, and long-range housing needs. This Housing Policy Plan and the technical resources that will follow will provide guidance to ensure that cities and townships coordinate their efforts to meet current and future housing needs and address regional and local housing issues. 

Met Council supporting housing development

Local Housing Incentives Account, Livable Communities Act

The Livable Communities Act (LCA) program (Minn. Stat. §§ 473.25 – 473.255) is a voluntary, incentives-based program that supports the development goals of both the Met Council and cities in the region. As of 2024, a suite of nine different grant programs provides funding to cities partnering with private developers and consultants to develop projects and policies that align with regional priorities. LCA programs prioritize and align with regional housing policy goals in several ways: creating more housing choice, supporting living wage job creation, and connecting jobs, housing, and regional amenities to create a more equitable region. 

To participate in LCA, cities and townships must adopt affordable and lifecycle housing goals and participate in the Local Housing Incentives program. Additionally, cities need to have adopted a Fair Housing Policy to receive grant funds if awarded. The LCA website offers resources and sample policies for cities to create a Fair Housing Policy.  

Through the LCA Policy Development grant program, cities and townships can receive funding to develop policies that will further LCA goals and impact physical development. To advance housing policy initiatives, this grant program financially supports increasing density allowances, adopting inclusionary zoning, and setting environmental standards for building projects, among other policies.  

Each of the grant programs prioritizes deeply affordable housing, affordable housing serving a special population, and affordable housing that includes on-site resident services. The Affordable Homeownership program specifically addresses racial disparities in homeownership opportunities, while all LCA programs place an emphasis on racial equity in development outcomes.  

Expanded technical assistance

The Met Council recognizes that local governments will continue to be the experts on needs at the local level and emerging needs among their residents. We will seek opportunities to support local governments through access to relevant data and technical assistance on regional housing issues and solutions. In this Housing Policy Plan, we commit to expanding the technical assistance we provide to local governments to support the local comprehensive planning process and the effective implementation of housing policies and programs.  

Housing is being developed, specifically affordable housing, in new areas of the region where cities and townships have not had as much experience adopting affordable housing policies and programming. The Met Council recognizes local staff capacity constraints and so will offer expanded technical assistance that will lead to stronger housing elements of comprehensive plans and will support housing development in cities and townships with little experience in working with affordable housing developers or adopting affordable housing policies and programming.

In addition to providing technical assistance, the Met Council researches and generates expertise on subjects about which communities are seeking a deeper understanding. We will provide a regional perspective on the strategies, challenges, and opportunities that are facing all communities in the region. Some of the subjects we have identified in this plan for the Met Council to pursue more research on include: 

• “Missing Middle” (small and medium multifamily, and attached single-family homes)
• The impacts of housing instability on the region
• Connections between affordable housing income limits and residents’ social and economic experiences
• The risk of inaction of meeting the housing needs of the region
• Alternative credit pathways 

The Met Council can also play a significant role in sharing best practices developed by other organizations around the region, state, and nation. Rather than replacing work done by other leaders in these areas, we will seek opportunities to amplify the work being done around the region as well as support the continuation of this work. Topics identified within the plan’s actions include:

• Anti-displacement
• Tenant protections
• Programs that expand regional housing choice
• Uses for new affordable housing funding
• Housing preservation and maintenance  
• Climate resilient housing practices  
• Fair housing 

Met Council staff will continue to serve as a resource for communities seeking research and best practices on housing strategies, tools, and opportunities. In addition to the commitments made in the actions of this plan, research and resources to assist with local program and policy development may include topics such as: 

• Manufactured housing
• Homelessness and instability
• Rental quality regulation
• Housing preservation
• Reparative actions
• Decarbonization 

Another area we have identified for expanded technical assistance is community engagement. Meaningful community engagement continues to be a challenge for governmental entities, including the Met Council, even as the importance of meaningful community engagement is better understood. Conducting meaningful engagement is an area of practice that will require continuous learning, evaluation, and improvement.¹⁰⁵ 

Partnerships

As a regional entity, the Met Council was formed to address issues that transcend local government boundaries and cannot be adequately addressed by any single governmental unit alone. The Met Council will use its regional role to be a convener of regional conversations, both in areas where we have statutory authority and around issues with regional significance. The Met Council also supports and uplifts the work being done by other regional housing leaders, including by being an active participant in that work. These are some of the areas identified in the actions above where the Met Council intends to convene collaborative regional discussions: 

• Improving the alignment of different affordable housing funding sources
• Impacts of housing instability on the region
• Coordinating social service and education providers to promote housing stability
• Promoting equitable access to stable housing
• Affordability limits and potential alternatives
• Best practices for anti-displacement mitigation strategies 

^101. In Thrive MSP 2040, the Future Need was measured in three income bands – 30% AMI or less, 31-50% AMI, and 51-80% AMI, with the largest share of needed affordable housing units at or below 60% AMI. Moderate-income households (60-80% AMI) were included to highlight the need for different affordable housing types such as townhomes, detached housing, and manufactured housing, with the goal to encourage private-market development of more affordable options, increase the availability of larger units, and provide opportunities for ownership. However, in practice, data shows that many rental units that are not required to be affordable are inflating the 51-80% AMI category, and many cities and townships have exceeded the needed creation of housing units in the highest income band, while also failing to meet the largest demand in the region—for housing units affordable to households at 30% AMI or less. For the 2031-2040 decade, Future Need will have a more focused approach, creating a smaller overall goal for the region that focuses on the households who are most at risk for housing instability.
^102. Metropolitan Council Affordable Housing Production dataset and Metropolitan Council Parcel dataset, 2020. 
^103. Affordable units are defined as those affordable to households with incomes that are 60% of the area median income or less, more information can be found in Metropolitan Council – 2024 ownership and rent affordability limits. https://metrocouncil.org/Housing/Planning/Affordable-Housing-Measures/Ownership-and-Rent-Affordability-Limits.aspx  
^104. Metropolitan Council (2024). Met Council housing policy and production survey. https://metrocouncil.org/Housing/Planning/Affordable-Housing-Measures/Housing-Policy-and-Production-Survey.aspx
^105. To see more about community engagement commitments, please see the Community Engagement Framework