Northfield Ave Realty Associates 81 Northfield ZBA Application Supplemental Submission 4425 002

WATERS, MCPHERSON, MCNEILL Diana Chandler-Zimmermann A PROFESSIONAL CORPORATION April 4, 2025 Page 4 to the Property/scenario at hand, and nothing set forth in the Planning Review Letter even remotely states that the parking at issue here is prohibited under the Ordinance. In fact, associating the word “required” with number as opposed to type of parking, further directly supports the point being made by Applicant here, in that in such an instance, there is still no prohibition whatsoever in the Ordinance on the type of vehicles that may be parked onsite at the Property, nor on the times of day or for how long they may be parked there. Thus, it is respectfully submitted that the Board’s focus in connection with this application be properly framed as to encompass the totality of the question presented, as same applies to the Ordinance, and confirming, however the Board prefers to frame the question, that the parking arrangement described hereunder is allowed (either because it is exactly what is contemplated/permitted under the Ordinance, or, alternatively, because there is nothing prohibiting it). Thus, for the reasons set forth both herein, and in the initial Application, it is respectfully submitted that the Board ought to interpret the Ordinance as permitting and/or in the alternative, not prohibiting the parking use described in the Application and herein, and issue a finding that such use is allowed under the Ordinance. Very truly yours, WATERS, McPHERSON, McNEILL, P.C. By: Cy? | a M. Spanarkel Enclosures #1638251v1