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/" :;?Â'%'~ INCORPORATED CONSULTING PLANNERS LANDSCAPE ARCHITECTS 300 FIRST AVENUE NORTH SUITE 210 MINNEAPOLIS, MN 55401 612·339,3300 (C(Q)fP){ 26 April 1991 Linda Bergquist Midwest Great Dane 1905 W. County Road C Roseville, MN 55113 Dear Ms. Bergquist: When we met recently to discuss the Special Use Permit application for National School Bus Company for their proposed bus operation on the Midwest Great Dane site, you requested the specific references from the Roseville Zoning Code that would require the property to be brought into conformance with the standards in the Code. I apologize for taking so long to get back to you with this information. Attached are copies of five pages from the Zoning Code and the Comprehensive Plan with certain sections highlighted. These references, in my own opinion, constitute sufficient justification for the City to require any Special Use Permit applicant to bring a property into full compliance with the standards of the zoning district in which it is located, and for this specific use on this site to do likewise. There maybe other references and other legal principles that could further support this conclusion. To summarize the references I have included here, the Puq>ose and Scope section (page 4) states that the Code requirements are for "regulating [the] alteration and use of buildings, structures and land", and that "no building, structure or land shall be occupied or used which is not in conformity with the regulations" of the Code, The section titled Existing Structures or Uses (page 74) states that "any nonconforming use may be continued, but may not be. , . changed unless to a conforming use". To be a conforming use in the 1-2 District, the "storage and maintenance of school and charter buses" must be granted a Special Use Permit (page 72). When such a permit granted, the City Council may impose "conditions as it deems necessary to protect the public health, safety, and welfare". This last phrase is the generally accepted justification for zoning regulations. The criteria for issuing a Special Use Permit (page 75) include "compatibility with the City's Comprehensive Plan", which is the foundation for most zoning requirements. The final page J have attached lists the industrial development policies from the City's current Comprehensive Plan. Among these policies are items stating that the City will "maintain and upgrade. . .