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<br />replacement of the 1-694 sign face with an LED display falls squarely within the definition of <br /> <br />an "improvement." <br /> <br />The City stakes out an extreme position, arguing that any "increase in one or more <br /> <br />dimensions of a structure or a use constitutes an expansion or enlargement of that structure or <br /> <br />use," and thus automatically converts an otherwise permitted improvement to a prohibited <br /> <br />expansion. Counterclaim 'lI8. The City relied on five factual findings in support of its <br /> <br />conclusion that the replacement of the sign face was an expansion rather than an <br /> <br />improvement. Again, these five factual findings were: I) that there was an increase in <br /> <br />i; <br /> <br />amperage; 2) that the number oflights on the sign increased; 3) that the new LED sign face is <br /> <br />approximately six inches deeper than the old face; 4) that the LED face weighs more than the <br /> <br />old face; and 5) that structural supports were added to support the new sign face. Sept. 10 <br /> <br />Tr. at 45. <br /> <br />In reaching these conclusions, the City wholly overlooked the bigger picture. <br /> <br />Although the LED sign face employs newer technology, this face is in other respects nearly <br /> <br />identical to the one it replaced. Not onJy is the new sign face almost the same size, but it actually <br /> <br />displays images that are smaller than its predecessor. McCarver Aff. 'lI11. And both the new LED <br /> <br />panel and the structural modifications supporting it are confined to the existing sign footprint. Id <br /> <br />Indeed, except for the updated image technology, the outward appearance of both the sign face and <br /> <br />(continued from previous page) <br /> <br />696-97 (1979) ("It is always appropriate to assume that our elected representatives, like other <br />citizens, know the law."). <br /> <br />13 <br />