CCP 11-25-1996 - Laserfiche WebLink

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I ~ ~. City of Arden Hills Page 3 October 1, 1996 I Arby's/Sbarro is looking for: . . .) . The business thus holds itself out as only one employer. Its public area does not distinguish between the two menus: it has only one condiment section, I and only one seating area. When the Arby's in West St. Paul decided to add Sbarro food items to its menu and revise its signage and logo, it advised the city that it was only remodeling the I existing restaurant. But perhaps most telling of all is the business owner's applications for restaurant licensing with I the State of Minnesota, and various municipalities. When applying for a license as a restaurant the Arby's/Sbarro sites seek and obtain only one license. If there were two restaurants at the site, an Arby's and a Sbarro, the licensing agencies would require two licenses. It is I disingenuous at this time for the business to claim that it is now two restaurants at this particular site when its operation will be identical to all those other Arby's/Sbarro sites currently operating with only one restaurant license. I Shannon Square has relied upon the fair enforcement of the City of Arden Hills' ordinances in making a substantial investment in this community. It would be inequitable to our client to I create an ad hoc exception to the plain meaning of the ordinance to accommodate this one developer. Such an action would also serve as precedent for other developers who wish to avoid the consequences and plain meaning of the ordinance. .. On behalf of our client we respectfully urge the commission to deny the request of the Saint Paul Companies to permit the construction of the restaurant on its site as a result of the traffic factor I and the failure to comply with the requirements of the City's ordinances. Very truly yours, I m & NJUS, P,A. i . (/i I e . Meyer I NMM/ssp ce: Hayzin, LLC I I I it nmm/hayun\plancom.ltr I