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PROCEEDINGS BEFORE <br />THE DANE COUNTY BOARD OF ADJUSTMENT <br />In Re: Appeal By Madison ) <br />Mobile Home Park, L.L.C., ) <br />of Zoning Inspector's ) Appeal No. 2812 <br />Interpretations of Zoning ) <br />Ordinance ) <br />BRIEF IN SUPPORT OF APPEAL <br />This Brief is in support of an appeal of the Zoning <br />Inspector's interpretation of our zoning ordinance as applied to <br />the lawful nonconforming use of a mobile home park. The Zoning <br />Inspector determined that any relocation or replacement of existing <br />mobile homes must comply with the spacing and off-street parking <br />requirements of the zoning ordinance adopted 20 years after the <br />park was developed. The park owner respectfully disagrees for the <br />reasons stated in this Brief. <br />BACKGROUND FACTS <br />Madison Mobile Home Park is an old mobile home park <br />constructed in the late 1950s. The 30 ft. spacing and off-street <br />parking requirements in §10.08 were not adopted until 10/30/76 by <br />Amendment #1797. <br />The mobile home park consists of 169 mobile home sites or <br />pads. Each such site or pad consists of permanent in ground <br />improvements for sewer and water connections; for gas and electric <br />connections; and for concrete foundations and patios. The mobile <br />homes are owner occupied. The tenants pay "ground rent" for their <br />occupied site or pad. <br />