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Larkin Larkin Hoffman Hoffman 8300 Norman Center Drive Suite 1000 Minneapolis,MN 55437-1060 General: 952-835-3800 Fax: 952-896-3333 Web: www.larkinhoffman.com March 12, 2021 Katie Larsen Via Email City Planner KLarsen@linolakes.us Lino Lakes City Hall 600 Town Center Parkway Lino Lakes, MN 55014 Re: Chris Stowe - 426 Pine Street NE, Lino Lakes, Minnesota Dear Ms. Larsen: This firm represents Chris Stowe, the owner of 426 Pine Street NE ("Property"), in the City of Lino Lakes ("City"). The Property is improved with an approximately 30,000 square foot riding arena ("Arena"), several acres, pasture land, and multiple agricultural buildings. This letter is intended to clarify Mr. Stowe's position regarding the lawful use of the Arena and contest the applicability of the 2020 conditional use permit(CUP) conditions the City is seeking to enforce against the Property. Background On October 14, 1968, the City approved a special use permit(the "SUP") for the Property to allow for a riding stable and Arena to be used for horse shows and horse boarding. At the time, the City had no limits on the number of animals that could be kept on the Property. Since that time, the owners of the Property have used the Arena and the Property for its approved purpose consistent with the SUP. In April 2018, Mr. Stowe acquired the Property and immediately began using the 30,000 square- foot Arena consistent with the SUP, including horse riding, horse shows, and horse boarding. Shortly thereafter, in direct response to complaints about Mr. Stowe's continuation of Arena operations, staff prepared a City Council staff report, dated July 9, 2018 ("2018 Staff Report") with recommended ordinance changes. At that time, City staff openly acknowledged that"the [Property] has operated as a horse training and selling facility for the past 20 years and is considered a commercial stable under the zoning ordinance." 2018 Staff Report Page 1. On July 13, 2018 the City passed Ordinance Number 10-18 ("Stable Ordinance"), establishing City Code of ordinances ("City Code") section 1007.058, which created numerous performance standards for Commercial Stables, including capping the maximum number of animals and requiring a conditional use permit(CUP).