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Zoning Bulletin November 10, 2011 [ Volume 5 1 No. 21 <br />drafters of the Code did not intend for the commercial boarding of hors- <br />es to be included in the definition of agriculture as a use for agricultural <br />purposes. <br />The court also rejected the LeComptes argument that § 5-3-4(A) of the <br />Code applied. Again, § 5-3-4(A) of the Code restricted the Village from <br />"impos[ing] regulations or require[ing] permits with respect to land used ... <br />for agricultural purposes." The court concluded that because the LeCompt- <br />es' property was used primarily for the commercial boarding of horses, <br />which was not a use for agricultural purposes, 5- 3 -4(A) did not apply. <br />See also: People v. Perry, 224 Ill. 2d 312, 309 111. Dec. 330, 864 N.E.2d <br />196 (2007). <br />See also: Cosmopolitan Nat. Bank v. Cook County, 103 111. 2d 302, 82 <br />111. Dec. 649, 469 N.E.2d 183 (1984). <br />Determination— Planning Board's Written <br />Denial of Application Fails to Enumerate <br />Reasons for Denial <br />Applicant says denial is inadequate, but Board says meeting <br />minutes detailed reasons <br />Citation: Limited Editions Properties, Inc. v. Town of Hebron, 201 1 WL <br />4398544 (N.H. 2011) <br />NEW HAMPSHIRE (09/22/11)—This case addresses the issue of <br />what is required for a local planning board's statement of the grounds of <br />disapproval of an application to be "adequate" under New Hampshire <br />statutory law. <br />The Background /Facts: Limited Editions Properties, Inc. ("LEP") <br />owned 112.5 acres of property in Hebron, New Hampshire (the <br />"Town"). LEP applied to the Town's Planning Board (the "Board ") for <br />approval to develop a 20 -lot subdivision on the property. The Board vot- <br />ed to deny the application. LEP appealed to superior court. <br />on appeal, LEP argued, among other things, that the Board, in disap- <br />proving LEP's application, failed to provide an adequate record "capable <br />of meaningful review." <br />New Hampshire statutory law, RSA 676:4, I(h) requires: "In case <br />of disapproval of any application submitted to the planning board, the <br />ground for such disapproval shall be adequately stated upon the records <br />of the planning board." <br />The superior court found the Board's record was sufficient and upheld <br />the Board's decision. <br />LEP appealed. <br />© 2011 Thomson Reuters 9 <br />