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Brian F. Leonard <br />Eldon J. Spencer, Jr.+ <br />Michael R. O'Brien <br />Edward W. Gale+j <br />Drover C. Sayre, 1110+ <br />Thomas R. Haugrud* <br />Peter M. Rosenc£ <br />Joseph J. Deuhs, Jr. <br />Thomas C. Atmore+ <br />Ernest F. Peake± <br />Matthew R. Burton° <br />James M. Jorissen+ <br />Peter J. Sajevic, llI' <br />Pamela H. Nissen <br />Scott S. Payzantno <br />Stacey L. Drentlaw+ <br />Jordan W. Sayre <br />Patrick J. Lindmark <br />LEONARD, O'BRIEN <br />SPENCER, GALE & SAYRE <br />Attorneys at Law <br />A Professional Association <br />100 South Fifth Street <br />Suite 2500 <br />Minneapolis, Minnesota 55402-1234 <br />Telephone (612) 332-1030 <br />Fax (612) 332-2740 <br />Internet: www.loso-s.cone <br />City of Ramsey Planning Commission <br />7550 Sunwood Drive NW <br />Ramsey, MN 55303 <br />June 6, 2018 <br />(VIA LJ S. MAIL AND <br />FACSIMILE 763-467-5543) <br />Andrea M. Hausercl <br />Michael T. Joliat <br />Paul M. Shapiro <br />Erika M. Peterson <br />Jenny (Chi) Zhang <br />Thomas W. Newcome <br />(1923 - 2011) <br />Thomas W. Newcome 111 <br />(Retired) <br />• Also admitted in Arizona <br />CO Also admitted in California <br />o Also admitted in Illinois <br />0 Also admitted in Iowa <br />Also admitted in Montana <br />} Also admitted in North Dakota <br />1- Also admitted in Wisconsin <br />Board Certified Civil Trial Specialist <br />(Minnesota State Bar Association) <br />t Board Certified Civil Trial Specialist <br />(National Board of Trial Advocacy) <br /># Certified Real Property Law Specialist <br />(Minnesota State Bar Association) <br />f. Fellow, American College of Employee <br />Benefits Counsel <br />Re: Objection to Revised Preliminary Plat (Master Plan) of Riverside Addition <br />Dear Planning Commissioners: <br />This office represents AKM Farm, LLC, the owners of PIN 19-32-25-41-0004 (Outlot C, <br />Northfork) and PIN 20-32-25-31-0002 (Outlot A, Alpha Development). The purpose of this <br />letter is to formally object to the Revised Preliminary Plat and Master Plan for the Riverside <br />Addition. <br />As an initial matter the proposed revised preliminary plat does not properly take into account all <br />buffer zone requirements prescribed by the City of Ramsey Zoning Ordinance. AKM's Outlot C, <br />Northfork property lies immediately to the west and AKM's Outlot A, Alpha Development lies <br />to directly to the northeast of the proposed Riverside Addition. As currently proposed, the <br />Riverside Addition development contains no buffer despite the fact that it is adjacent to the two <br />AKM Farm parcels, which are a different density designation. According to Ramsey City Zoning <br />Ordinance the proposed Riverside Addition must contain some level of buffer and transition to <br />these two adjacent parcels since they are not the same level of density. More specifically, City <br />Ordinance Section 117-110 states that the purpose of residential development transitioning is to: <br />[R]equire a residential development transition plan in order to promote orderly <br />transition between residential developments. The historical platting of lands for <br />urban and rural residential development has created character elements that are <br />difficult to intermingle when the land use densities vary. This section provides <br />techniques to mitigate lot size and density impacts between residential <br />developments. <br />The ordinance goes on to provide a number of different options to create appropriate buffer <br />zones between residential developments, especially when the developments will have differing <br />densities. Currently, the Riverside Addition density is significantly higher than the Outlot C, <br />Northfork Parcel and therefore the City should establish an appropriate buffer zone between <br />