Objector WeCare Response dated May 4 2026 to Letter of Bryan D Plocker Esq

including the question of the absence of a second means of ingress and egress. The Board then voted 9-0 in favor of its full list of concerns for the applicant and its mechanism for dealing with them. The single way in and out of this site is hardly a new concern. In April 2006, when the Planning Board denied a much smaller development application for this site by this applicant, it did so primarily on the ground of there being only a single way in and out and thereby creating serious safety concerns. The Board then put it this way: The Board concludes, based on the testimony of Mr. Gregor [objectors’ engineering expert], Mr. Litwornia [objectors’ traffic expert], Ms. Borg [West Orange’s full-time planner], and Mr. Lepore [West Orange’s full-time engineer] that the proposed 136 single family subdivision with only one access route and insufficiently wide roadways creates dangerous and inefficient vehicular ingress and egress to and within the site.…Additionally, the Board finds that a development of this magnitude having only one means of ingress and egress creates an inefficient network of roads that is contrary to the goals and intent of the Master Plan of the Township of West Orange, which encourages providing more than one road into and from a neighborhood rather than developing enclave type neighborhoods.” (Doc. PB-04-24 at 4).2 This statement from the Board’s 2006 decision is ever the more compelling today. At the time of this denial, the application concerned only 136 homes, whereas the present application concerns 496 residential units, almost four times larger. It is clear that if the lack of an additional means of ingress and egress was critical and compelling for this Board 20 years ago for a project nearly four times smaller, it is exponentially more important and compelling today. Yet, the applicant simply refuses to address the question offering no answer to the Board’s very pertinent inquiry. Mr. Plocker does not deny that the project exceeds the ADT maximum for this site. Instead, the applicant tries to push the issue under the rug by stating, “While it is understandable to focus on ADT, there is nothing in the Board record to suggest that the regular use of Warner Road and Oval Road is unsafe under existing conditions or would pose a safety issue after the proposed development is constructed.” See Letter of The Board also found at that time

egular use of Warner Road and Oval Road is unsafe under existing conditions or would pose a safety issue after the proposed development is constructed.” See Letter of The Board also found at that time that “the Application, as presented, failed to provide a sufficient tree2 plan” because it did not “provide an accurate count of the trees it proposes to remove from the site.” Doc. PB-04-24 at 4. The current application provides no count at all of the number of trees proposed to be removed or proposed to be replaced. 7