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Larkin Hoffman <br />October 1, 2025 <br />Mayor and City Council <br />City of Ramsey <br />7550 Sunwood Drive NW <br />Ramsey, MN 55303 <br />8300 Norman Center Drive <br />Suite 1000 <br />Minneapolis, MN 55437-1060 <br />General: 952-835-3800 <br />Fax: 952-896-3333 <br />www.larkinhoffman.com <br />Via Email <br />Re: Opposition to iDigital Outdoor's Appeal of Variance Granted for Off -Premise Digital <br />Billboard at 6111 Hwy 10 NW, Ramsey and Letter in Support of Kenjoh CUP <br />Mayor and Members of Council: <br />Our firm represents Kenjoh Outdoor Advertising, LLC ("Kenjoh"). Kenjoh applied for, and was <br />unanimously granted, a variance by the Planning Commission for the installation of a digital <br />billboard at 6111 Hwy 10 NW (the "Site"). The staff report, the unopposed testimony presented <br />at the duly noticed public hearing, and the Commission's written findings all confirm that <br />Kenjoh's variance application fully satisfies the requirements of the City Code and Minnesota <br />law. <br />As explained in greater detail below, iDigital's appeal is procedurally and substantively deficient. <br />The Planning Commission's approval of the variance was both proper and well -supported, and <br />the record compels the conclusion that Kenjoh's conditional use permit (CUP) application <br />should likewise be approved by the City Council. <br />I. Background and Project Description <br />Kenjoh is an independent, minority -owned operator of off -premise signs ("Billboards"), licensed <br />in Minnesota and multiple other states. Several months ago, Kenjoh identified the Site as a <br />favorable and marketable location for a digital billboard (the "Proposed Sign"). Through its due <br />diligence, Kenjoh confirmed that the Proposed Sign would comply with all height, lighting, <br />design, and size standards under the City Code. However, because of the location of existing <br />billboards and the City's two-mile spacing requirement, it was mathematically impossible to site <br />an additional billboard without a variance. <br />In consultation with City staff, Kenjoh appropriately determined that a variance from the <br />Planning Commission was required before pursuing a CUP from the City Council. The City <br />Code expressly allows up to three billboards along Highway 10, provided they are at least two <br />miles apart. Yet because iDigital already controls the only two existing billboards — one on the <br />west side of town and the other near the City center — a variance was necessary to realize the <br />third location contemplated by ordinance. In fact, the central location approved for iDigital is <br />itself less than two miles from Ramsey's eastern boundary, creating precisely the "practical <br />difficulties" that justify the variance now at issue. <br />Since Kenjoh objectively met all of the height, size, and other limitations imposed in the code for <br />a CUP, and it confidently anticipated compliance with the "practical difficulties" and other <br />