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