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Mr. Jacob Steen <br /> March 29, 2021 <br /> Page 2 <br /> You specifically suggest in your letter that the City conceded in a July 9, 2018 staff <br /> report related to its consideration of zoning text amendments to allow limited commercial <br /> stables in the rural zoning district that the Pine Street property had been used as a stable <br /> continuously for the last 20 years. You have also misread those reports. The property being <br /> referred to in those comments is a stable located at 1288 and 1325 Main Street. You will <br /> note that the July 9, 2018 report discusses the site that had been operated for the prior 20 <br /> years as a "horse training and selling facility". That is the Main Street property, not the <br /> Pine Street property. <br /> As you are aware, under Minnesota Statutes § 462.357, subd. 1(e), nonconforming <br /> use rights are lost if the use is discontinued for a period of one year or more. City Code <br /> contains similar language. Because the Pine Street property has not operated as a stable <br /> since 1994, it has lost any nonconforming rights it may have had under the 1968 CUP. <br /> Instead,it is subject to the present provisions of the zoning ordinance,which impose animal <br /> unit limitations on such operations. Your client has been granted a CUP allowing the <br /> maximum number of horses allowed by pertinent provisions. <br /> In summary, given the above, your client has no right to maintain on the site horses <br /> in excess of the number allowed by the 2020 CUP issued to him. If the conditions are <br /> violated, the City will pursue enforcement,up to revocation of the CUP. If your client does <br /> not execute the 1968 CUP termination agreement referenced in condition 14 to the 2020 <br /> CUP, your client will also be in violation of the CUP, which could also result in CUP <br /> revocation. <br /> Very Truly Yours, <br /> /s/ <br /> Jay T. Squires <br /> cc: Katie Larsen <br /> Mike Grochala <br /> RASW: 182024 <br />