Green Acres Letter

SPRINGFIELD │ NEWARK │ VOORHEES │ ELIZABETH | UNION | ELMWOOD PARK │MORRISTOWN | SUMMIT | CHERRY HILL | VINELAND │ | NEW YORK │ATLANTA | Stephen F. Hehl Anita Lynn James Steven H. Merman Natasha Montalvo Trevor J. Endler Maria Kelly Certified Trial Attorneys 370 CHESTNUT STREET UNION, NJ 07083 TEL: (908) 687-7000 FAX: (908) 687-7028 www.lawjw.com March 10, 2026 Via FedEx & Electronic Mail: ZoningBoard@westorange.org Mr. Philip D. Neuer Esq., Zoning Board Chairperson Zoning Board of Adjustment TOWNSHIP OF WEST ORANGE Town Hall 66 Main Street West Orange, NJ 07052 Re: Application for Bulk “c” Variance Approval Applicant: Pardo Development Group, Inc. Property: 104 Winding Way Block: 46.01 Lot: 33 Application No.: ZB-24-17 Dear Chairperson Neuer and Members of the Board: As you are aware, this office represents the Applicant, Pardo Development Group, Inc., with regard to the above referenced application. Kindly allow this letter to clarify the issues identified by the Board at the last hearing on this matter surrounding available neighboring property. As discussed during the last board meeting, the property is surrounded on two of three sides by the Rock Spring Golf Course. As this Board is aware, the Golf Course was purchased by West Orange and is operated by a private entity. Additionally, this property was purchased and placed in the town’s Green Acres inventory. Due to this designation, it is unavailable to be purchased by an individual or entity without subsequently replacing the land in the Township’s inventory with another parcel of land. Hence the issue of this lot being undersized cannot be fixed by purchasing adjacent property from the municipality. Our office has received copies of the documents involved in designating the property Green Acres from an OPRA request of the town. We can provide copies of the responsive documents if requested but are not attaching them to this letter due to their large quantity.

SPRINGFIELD │ NEWARK │ VOORHEES │ ELIZABETH | UNION | ELMWOOD PARK │MORRISTOWN | SUMMIT | CHERRY HILL | VINELAND │ | NEW YORK │ATLANTA | Should you have any questions or concerns, please do not hesitate to contact this office. Respectfully Submitted, /s/ Stephen F. Hehl STEPHEN F. HEHL SFH:tje cc: Kelly M. Carey, Esq. via email Ryan MacNeill, PE via email Christopher Dochney, PP, AICP via email Pardo Development Group, Inc. via email manTERRA Design LLC via email DantasCarrete Architecture via email John McDonough, PP via email John Barree, PP via email