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<br />than merely repair, restoration, or maintenance. See Minn. Stat. 9 645.16 (interpretative <br /> <br />I <br />I <br /> <br />canon that a statute should be construed to give effect to all of its provisions). By necessity, <br /> <br />an improvement must involve some physical change to the non-conforming structure. See <br /> <br />Lietz, 718 N.W.2d at 869 (defining an improvement as a physical installation that is <br /> <br />"distinguished from ordinary repairs"). <br /> <br />To construe Section 462.357 as the City proposes - such that modest physical <br /> <br />alterations are prohibited - would effectively write the word "improvement" out of the <br /> <br />statute. The Court should reject this unreasonable construction of the statute. <br /> <br />m. THE LIGHTING PROVISIONS OF THE CITY'S SIGN CODE CANNOT BE <br />ENFORCED AGAINST THE 1-694 SIGN. <br /> <br />In denying Clear Channel's sign permit application, the City relied, altematively, on <br /> <br />the Sign Code's requirement that freestanding signs in Sign District 7 are limited to extemal <br /> <br />lighting. But this requirement is inapplicable. The City lacks the necessary State approval to <br /> <br />enforce its municipal lighting restrictions against the 1-694 sign. Even if the City had such <br /> <br />approval, the lighting restrictions ofthe Sign Code do not apply to billboards. In any event, <br /> <br />the external lighting requirement relied on by the City is arbitrary and unenforceable. <br /> <br />A. Lacking State Certification, The City Cannot Impose Its Own Lighting <br />Restrictions On The 1-694 Sign. <br /> <br />Because the 1-694 sign is adjacent to an interstate highway, the Minnesota Outdoor <br /> <br />Advertising Control Act applies to this sign. The Outdoor Advertising Control Act, Minn. <br /> <br />Stat. Ch. 173 ("Outdoor Advertising Act" or "the Act"), whose major provisions were passed <br /> <br />in 1965 and 1971, is designed to accomplish the purposes of the Federal Highway <br /> <br />Beautification Act and to bring state law into compliance with federal law. Minn. Stat. 9 <br /> <br />173.01. Under the Act, outdoor advertising signs located within commercial or industrial <br /> <br />15 <br />