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{ <br /> Topf Wells <br /> January 2, 1996 <br /> Page 2 <br /> apply an analogous test in determining a threshold of "substantial earnings" in evaluating <br /> whether an applicant qualifies for benefits. The Social Security Administration guidelines <br /> are set forth in 20 CFR Ch. 111, sec. 404.1574 (4-1-95 edition). The Social Security <br /> Administration uses a figure of$500 per month averaged over the calendar year as the <br /> threshold level of eligibility. We suggest the zoning administrator adopt this as the dollar <br /> value equivalent of substantial income. <br /> Please note that as to 'secondary farm residences',the ordinance provides, at sec. <br /> 10.123(2)(c), that the qualifying test is that the applicant earn "a substantial part of his or her <br /> livelihood from farm operations on the farm." Note that this is different from substantial income <br /> in that now the requirement is to look at one's total income and use farm income as a comparison <br /> with total income. Here the zoning administrator might use a percentage calculation. While <br /> thirty percent would be defensible, it does seem somewhat high. We suggest 25% or even 20% <br /> be used. <br /> Sincerely, <br /> • <br /> C W. Kornstedt <br /> Corporation Counsel <br /> • <br /> exe-$2 <br />