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-� <br />Members of the Roseville City Council <br />November 23, 2010 <br />Page 7 <br />�. <br /><��E�. <br />Moss & Barnett <br />but not limited to, Gladstone's. The piles of rubb�e will not be adequately buffered and anyone <br />traveling to and from Gladstone's building and the building users will be in an area <br />characterized by piles of rubbie. The 40 feet tall piles of rubble would directly undermine the <br />marketability of Gladstone's office building. Other properties will suffer the same ill-effects. <br />The previous anafysis by the Planning Commission was undertaken without the benefit of the <br />extensive public discussion, and the analysis and scientific study completed by Gladstone, Old <br />Dutch and others, which has taken place during recent months. The initial review relied on the <br />concept that designation of the area as an I-2 Industrial District was su�cient grounds for <br />making findings regarding the conditional use criteria. That approach fails to take into account <br />the multiplicity of permitted uses in the area that would be adversely affected by the outdoor <br />storage as well as the outdoor storage and asphalt piant taken together, No conditions in the <br />proposal or any that would enable the project to proceed, would solve the problem. <br />It wou/d distort rea/ity to rnnsider the ouGdoor storage as ifthe aspha/t p/ant were <br />a/so notpartofthe proposed use. The asphalt piant is the only reason for the outdoor <br />storage. Future outdoor storage of the type proposed by Bituminous would not satisfy the <br />criteria or enable the Council to make the findings required for granting the conditional use. <br />^ Thank you for the opportunity to comment regarding the asphalt plant and to make certain that <br />the record inciudes the Letters, our September 21, 2010 letter, the November 18, 2010 letter <br />from Patrick Mulloy, and this letter. <br />Very truly yours, <br />� � .'? , <br />✓ i `� � <br />��/�. ��' ; �yi��,,•�-.1 <br />Paul B. Zisia i� <br />Attomey At Law � <br />P:(612) 877-5328 <br />Z islaP@moss-ba rnett. com <br />PBZ/cag <br />Enclosures <br />cc: Mr. William Matinen, City Manager (w/encl,) <br />Mr. Chris Massey (w/encl.) <br />Mr. Chris Giiedman (w/encl.) <br />Ms. Caroline Bell-Beckman (w/encl.) <br />1703296v3 <br />