Christa Westerberg is a lawyer with Pines Bach, LLP of Madison, Wisconsin who represents one of the homeowners adjacent to the proposed sand mine, Laura and Ron Scott. She has written a legal opinion to the Waupaca County Planning and Zoning Committee that will be read at Wednesday’s 1 pm meeting.

In the letter, Westerberg says “There are many reasons the CUP can and must be denied. For example, the CUP application is incomplete, as we have already explained in correspondence to the Town of Scandinavia dated December 12, 2022.”

She adds that the neighbors will show “substantial evidence” of harm to their home values and quality of life at the Wednesday meeting and then concludes with this statement:

“The Town of Scandinavia has demonstrated, through its planning committee and town board, that the proposed CUP will not be consistent with all relevant aspects of the Town’s comprehensive plan. This is required not only by the Zoning Ordinance, ch. 34, § 14.5(1)(b)(3), but by the Non-Metallic Mining Ordinance, ch. 38, § 27.1.4(b). The Town’s decision and reasoning are exhaustive and should be followed by this Committee.”

Click on the button below to read the entire letter that will be read at Wednesday’s 1 pm meeting.