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(~AFIY C r-,iEITER <br />JOSEPH M (.~OLDBFRG <br />RANDEE 5 HELD <br />MARK J MANDERFELD <br />,~AY [~ Ur~NESS <br /> <br />JAMES ~V~ LEHMAN <br /> <br />M/~,~I'(~f4EY, DOUGHERTY AND MAHONEY <br /> PROFESSIONAL ASSOCIATION <br /> <br /> ATTORNEYS AND COUNSELORS <br /> <br /> 801 PARK AVENUE <br /> MINNEAPOLIS, MINNESOTA 55404-1189 <br /> <br /> PHONE (612) 339-5863 <br /> TELECOPIER 1612) 339-1529 <br /> <br />INCLUDING THE PRACTICE OF <br /> MILLER & NEARY <br /> <br />~.~REGORY A ZINN <br /> <br />SANDRA J (~ROVE ' <br /> <br />G.J MAHONE¥ fl923-$~9) <br />R.J NEARY i192g 19El4) <br /> <br />NovemOer 26, i99i <br /> <br />Ms. Sylvia Frolik <br />Zoning Administrator <br />City of Ramse¥ <br />15153 Nowthen Boulevard N.W. <br />Ramsey, MN 55303 <br /> <br />Re: <br /> <br />PIN 29-32-25-11-0010 <br />Rezoning of Lot 2, Block 1, HY-10 Ramsey 4th Addition <br />Our File #91-4750-09 <br /> <br />Dear Hs. Frolik: <br /> <br /> Our office represents James and Rita Amble, the owners of the <br />above property presently zoned as an Industrial ("I") District <br />which the City is considering rezoning to a Rural Industrial <br />("R-I") District. <br /> <br /> In reliance upon the zoning at that time, the Ambles purchased <br />the property on July 6, 1989 for $25,000 to use as an outdoor <br />storage facility for their business. At the time of its purchase, <br />the property was a cornfield which the Ambles have had to grade, <br />surface and fence at a total additional cost of $23,700. The <br />present surface of the property consists of grass and gravel which <br />amply controls dust. When they first purchased the lot, the Ambles <br />applied for a permit to construct a pole barn for inside storage <br />but this was refused. Now, the City is trying to limit outdoor <br />storage and has allowed the construction of a pole barn on a <br />neighboring property. <br /> <br /> As you know, a "supply yard" is a permitted use in an "I" <br />District under § 9.21.26 subd. 2(e) of the zoning ordinance. For <br />our purposes, the major difference in the Rural Industrial zoning <br />ordinance is that a supply yard is not a permitted use. If the <br />rezoning were to take place as proposed, the Ambles would be left <br />with two choices if they wished to continue using the property as a <br />supply yard: <br /> <br />Continue their operation as a <br />nonconforming use wi th the requisite <br />uncertainty of that status; or <br /> <br />CERTIFIED AS A CIVIL TRIAL SPECIALIST BY THE MINNESOTA STATE BAR ASSOCIATION. <br /> <br /> <br />