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' 27-CV-14-7419 <br /> 18. The Plaintiffs also petition for an injunction enjoining Orono from enforcing <br /> its violative ban. <br /> COUNT II <br /> COMPLAINT FOR DECLARATORY JUDGMENT <br /> � Under Minnesota Statute�� 555.01, et seq. <br /> VIOLATION OF STATUTORY PERSONAL INTERESTS <br /> 19. The above paragraphs in their entirery are hereby incorporated by reference <br /> heYein. <br /> 20. On December 9, 2013, the City of Orono adopted a complete ban on Small <br /> Wind Energy Conversion Systems. <br /> 21. Orono Ordinance No. 119,T'hird Series, is a complete ban on wind energy <br /> conversion systems: <br /> "Wind energy conversion systems are not an allowed use or structure within <br /> any zorung districts in the city." <br /> Orono Ordinance Sec. 78-1379,Alternative Energy Systems, subd. (6). <br /> 22. The Orono ban on sma11 wind energy conversion systems applies to <br /> businesses and homeowners. <br /> 23. The Orono ban on small wind energy conversion systems violates the <br /> personal rights established by Minnesota Statute e. § 216F.02(b) which prohibits local <br /> governments from enacting complete bans on businesses and homeowners using SWECS to <br /> generate electricity. <br /> 24. As part of Minnesota's energy culture, through enacted laws and policies, the <br /> State has encouraged the development of innovations to be made available its citizens to <br /> 5 <br />