I

2. SHOULD EVERYONE BE ABLE TO DO THAT?  Why should PREIT be able to do that unless everyone else can? That makes the code fairly meaningless, doesn’t it?

3. ARE THE COMMISSIONERS ALLOWED TO VIOLATE THEIR OWN  ZONING  CODE WHENEVER THEY DON’T LIKE IT ?   Don’t citizens have a right to have their zoning laws ( and codes, etc)  upheld? 

4. NON-CONFORMITIES MUST BE RECTIFIED PER OUR CODE, ISN’T THAT RIGHT?  Our zoning ordinance requires that all nonconformities get rectified before any additional development takes place on a property.  Why would PREIT not have to follow that code if everyone else does? Lack of GreenSpace ? Other nonconformities ? 

5. WHAT SHOULD THE BUSINESS DISTRICT'S RESPONSIBILTY  TO GREENSPACE  BE ? Almost all of the residential zoning districts in the Township require  close to 50% of greenspace - which cleans the air, helps manage stormwater, etc.  Why do business districts shoulder less of that very important burden ?  

 6. ONCE APPROVED, ISN’T IT TRUE THAT   PREIT / BEL CANTO / BLOOMIES IS NOT REQUIRED TO BUILD WHAT WE WERE  REPEATEDLY SHOWN ? They would have the right to build anything that meets the ordinance - it  could be quite different, couldn't it ? Or they could sell the improved property for a greater value to another entity.

7. IS IT FRAUD TO REPEATEDLY SHOW SOMETHING, LIKE ONE BUILDING,  WHEN WHAT YOU ARE REALLY ASKING FOR IS SOMETHING ELSE ENTIRELY ?   It is also exactly what was done at the YMCA/BET/Abington Terrace?CHOP project, isn't it ? For a year they showed a senior residence. Got the zoning an immediately built a medical facility that no one had had any say in. And very similar tactics were used at Penn State Abington, passed Nov 10, 2021, which autorized other buildings but did not show the extent of that in public.  It is another form of fraud, isn't it? Fraud is "  a deliberate act with the intention of obtaining an unauthorized benefit, either for oneself or for the institution, by using deception or false suggestions or suppression of truth or other unethical means, which are believed and relied upon by others.

8. SO...HOW MANY OTHER BUILDINGS ARE BEING IMAGINED IN AN ORDINANCE THAT SPEAKS OF MASTERPLANS AND SUBDIVISIONS?   Marc Kaplin even suggested at one meeting that even that first building might  not be 365 units, didn’t he?  Then he showed a building in Macy’s parking lot  that belied his earlier denials. But still MORE wer possible on Goodman's properties and the At Home property?  You can't  put in writing that you are going to build just the one building with 365 units  can you ...because  that would be spot zoning, and would be illegal, wouldn't it ? Ypu'd have one property treated differently than the others. After 11 meetings we still don't have an answer as to how many can be built, do we? Can you answer that now? 

9. THE FINANCIAL ANALYSIS WAS JUST FOR ONE BUILDING  no other buildings were included - even though more can  be built under this ordinance . The number of similar buildings was not shared, was it ? So the financial analysis was  not only incomplete, because it didn’t consider other buildings, but it was an imaginary thing that you may not even build. What are the finances on the maximum units that could conceiveably be built there? Couldn't the number of students  to our schools could greatly up-end any financial benefit? Isn't this vitally important to know?

10. HOW MANY ACRES EXISTS WITHIN THE 2500 LINEAR TOD DISTRICT  . At 16 units per acre -- we still don't have a firm figure on the acreage that applies.   How many acres times 16 units are possible ?  Why are you withholding the acreage?  

11. WHAT LIMITATIONS MIGHT PREVENT  A FULL 16 UNITS PER ACRE ON ALL OF THE TOD ACREAGE? If there is no place to put the required 3 acres of greenspace, for instance,  or other limitations , what are they  and how would that diminish  the final # of possible units ? 

12. WHY WEREN’T THE OTHER POSSIBLE PROPERTIES DISCUSSED ?  Why have you refused to discuss all possible  buildings  for  11 full meetings when you have been asked so many, many times?  What possibililies for subdivisions exist? How many meetings is the magic number of meetings  residents must attend to finally learn these things? It certainly looks like you are hiding something, doesn't it?

13.  THERE IS/WAS NEVER ANY  BUILDING APPLICATION FOR A 365 UNIT ALL RESIDENTIAL BUILDING BEFORE THE BOARD, ISN’T THAT CORRECT  ?   Only an ordinance for multiple buildings. So how is it reasonable for  us to have spent so MANY hours on one building that isn't even required to be built and doesn't fit the guidelines of your ordinance anyway?  since I think it is clear Abington is losing $ on the first one that we saw, isn't it?

14. HOW MANY MEETINGS IS REASONABLE TO DRAG RESIDENTS THROUGH -  while Commissioner refuse to ask their own questions or questions on the publics behalf or to demand the public get answers or  the project will simply be denied. It loos a lot like collusion between the builder and the Commissioners, doesn't it? 

15. IF NO OTHER BUILDINGS WERE  ALLOWED BUT BEL CANTO'S, THEN ISN’T THIS ILLEGAL SPOT ZONING ?   If you  made your hand picked specs with guidelines that made them only apply to the one 365 unit building, then that would be illegal spot zoning, where you picked conditions that excluded others. Isn’t that correct?

16. WHY DID PREIT NOT USE THE STANDARD TOD  ½ mi  2650 FT FROM A TRAIN ?  Why did they  change it to 2500 ft ? Who did they intend to leave out? Doesn’t that again confirm spot zoning -- because you  are choosing exactly what properties are in and out of the benefit  you  are heaping upon yourselves and ....some others ?? 

17.HOW COULD AN ALREADY EXISTING  RETENTION POND QUALIFY AS THE GREENSPACE THAT THE NEW BUILDING IS REQUIRED TO PROVIDE?   It was already there -- do they get to remove 3 acres of  GreenSpace  from PREIT  in the process of adding their 3 acres for Bel Canto.  3 acres is not being  “added” -just  “ swapped out”. Do you imagine that is the intent of the requirement? Is this another fraud?

18. IS THE BUILDING THAT YOU HAVE BEEN SHOWING US COMPLIANT WITH YOUR OWN ORDINANCE?  ...which requires a mix of commercial and residential – 10% apartments and  20% of commercial is required in your ordinance. The building you have been showing has only residential. Please explain.

19. THE WHOLE POINT OF ADDING THE RESIDENTIAL WAS TO REVIVE THE MALL, WASN’T  IT? – and there was never enough parking for it at the holidays in years gone by. (Pre-Covid) So if you give the parking lot away to Bel Canto and the mall is revived, which is the goal,  and has even more cars than are parked there now, won't they  need another parking garage ? 
PREIT published one picture showing Bloomies lot full -up in 2021.

20. ABINGTON RESIDENTS DON’T PREFER PARKING GARAGES Mr. Kaplin was part of the Fairway Transit District efforts and must recall residents vehemently testifying that they did not want parking garages. Does he recall that testimony or should it be provided for him and for PREIT? These are the suburbs, aren't they?

22. IT’S NOT WRITTEN ANYWHERE IN THEIR ORDINANCE THAT THEY ARE LIMITED TO 14 KIDS TO THE SCHOOLS, IS IT?  And isn’t it true that PREIT had to declare bankruptcy, because apparently both their math and their management was not as sound as it should have been. Shouldn't this concern all of us that currently student generally can be 22-29 % of the appartments per the School's account. Her's some of that bad math - retirees that they consider childless couples who want to stay close to the friends and family nearby in Abington, will be leaving a  house that will be bought by a family that will bring additional kids to the district. Seniors out - families in.

23. THE COST PER STUDENT WAS SERIOUSLY PERVERTED in the Angelides report wasn't it?  They decided that the Bel Canto students would not have to bear the same costs as the other students do. They used 13,500 is the cost per student  -------------  so okay if it is the cost per student for Bel Canto students,  than it’s the cost per student for all students.  But then ... someone has to pay  the cost of debt service, federal grants that come from taxpayer dollars etc. Somehow the Angelides financial report decided that all the OTHER  students should bear those costs but the Bel Canto students should not. If you take all the costs and divide them among ALL the students, the cost is somewhere around $21,000- $22,000 per student not $13,500.  It was simply a flawed report that gave unrealistic numbers, wasn’t it?  Even the number of students....

24. BEL CANTO DECIDED THAT NONE OF THE 3 BEDROOM APARTMENTS WOULD HAVE ANY STUDENTS.... . because their  appartments are so expensive they decided all the children would go to private school .  Doesn’t that seem unrealistic, for apartments  in a school district where people often choose to live in our Township just because of the schools ?  Three bedroom apartments might have as many as 4 students.  Nothing is in writing that would prevent that, is it?

25. BEL CANTO IS PROVIDING  NO PARKS OR REAL  RECREATION  FACILITIES FOR ITS OVER 500 RESIDENTS, ARE THEY?  Do they imagine that “uppercrust",  "well to do”  tenants don’t  look for outdoor amenities  and  a pleasant  environment - that a mall parking lot next to a busy street with only a walking trail around a pond would be sufficient ?
That seems unrealistic to me, so shouldn't we talk about what happens if you can't rent them for those prices? With or without children ? 

26. WON'T DIFFICULT TO RENTAPARTMENTS LIKELY BECOME SUBSIDIZED,”AFFORDABLE" HOUSING?  - "affordable housing” units sometimes require the tax payers to pick up 60% of the rent. To create affordable housing units we shouldn’t be subsidizing luxury apartments, should we?  I don’t believe any affordable housing subsidies that could burden the taxpayer were evident in the Angelides report.  Wouldn’t they be necessary for a proper analysis?  Since more children come from apartments that cost less per the Angelides report- those expnsive subsidized homes would necessarily fall into that category, wouldn’t they?  So far more children would be expected to attend our schools as the rate of subsidized housing went up. Isn’t that true?

27. THE INTENTION TO PROVIDE HOUSES FOR SENIORS  WILL ACTUALLY BRING MORE CHILDREN TO THE SCHOOL DISTRICT THEN HAS BEEN CONSIDERED, WON’T IT?  In an effort to provide seniors with apartment living when they are ready to give up their home, an unintended consequence is that a family will move into that vacated home,  so multiple children may be added to the district for every senior retiree family who comes from Abington.  Those children have not been counted in the Angelides report, have they?  How many retiree families from Abington do you expect you might have as tenants?  Isn’t that one of your prime goals - providing local retirees an opportunity to stay near their friends and loved ones?   Where is the calculation of the tax burden for these possibilities?   

28. DANGEROUS INTERSECTIONS   Families who would like to live near transportation  are going to have to cross streets that are becoming quite  over trafficked , with this development adding, perhaps, 500 cars a day or more, and some who may even take multiple trips each day, right through the nearby intersections. Wouldn’t you agree  the tenants will have to consider a serious safety issue? 

29. TAKING THIS IN CONJUNCTION WITH THE COMPREHENSIVE PLAN Won’t these intersections  then REALLY take a hit if and when the current Comprehensive Plan Future Land Use  map is approved?  That map would allow mixed residential throughout the Willow Grove Park Mall Business District and through dozens or scores of neighborhoods  that will also be coming to Willow Grove to shop.  How would all of that added residential in conjunction with the impact from THIS developmnet affect the intersections like Easton Road and Moreland Road  or Old Welsh and Fitzwatertown? Has anyone considered this?

30. WHERE WAS THE CALCULATION OF THE TAX BURDEN FOR IMPROVEMENTS TO THE INTERSECTIONS & ROADS ? Some intersection improvements were done right before the application was made public ….  But obviously those behind the scenes knew what was about to come.  Where’s the calculation for those improvements, for intersection adjustments and for roadway modifications,  as a financial burden to the taxpayers? Was that in the report ? I fear it was missing.

31. NON-COMBUSTIBLE MATERIALS  ARE SAFER, AREN’T THEY ?  A very recent court decision  prevented us from imposing our  non-combustible ordinance on property owners that have the right to build something anyway. But these property owners do not have the right to build what they are requesting. So the Commissioners are under no obligation to approve this ordinance.  Abington very clearly decided that noncombustible construction was safer for its residents and therefore also more cost-effective because the costs of a fire can be devastating and affect Township resources dramatically.  Commissioners have a right to ask, not compel, a property owner to use non-combustible materials, don’t they ? And the commissioners also reserve the right to turn down a proposal without having to state any reason, don’t they?  

32. CORRUPTED PLANNING COMMISSION MEETINGS SHOULD NOT COUNT AS PLANNING COMMISSION MEETINGS AND SHOULD HAVE BEEN RESCHEDULED,   SHOULDN’T THEY?- despite a requirement for Planning Commission review, those meetings were corrupted in multiple ways and the corrupted meetings were not held again with the problems fixed. In one meeting , the Chair stated at the outset that they were not going to vote they were just going to pass the minutes on to the commissioners- that is contrary to Planning Commission rules, isn’t it? In another meeting the lawyer for the applicant interrupted the vote in the middle of the vote when he saw it going differently than he wanted, and he lobbied for the vote he wanted right in the middle of the vote taking.  That meeting was not declared null and void and re-held, was it? But it should have been, shouldn’t?

33. SUBDIVISIONS OF THE CURRENT PROPERTIES IS ANTICIPATED:   There is a requirement to have a "Master Plan"  when subdividing and building on other parts later.  PREIT has continued to put forth the pretense that only one building is what they request. ---  that being even directly stated at the last  (11th ) meeting on 10-14-21.  Yet, that would be spot zoning – and is  disingenuous at the least because you certainly don't need a Masterplan  when building one.  Isn’t that really a form of fraud when you tried to tell people something that’s not true in order to get something that you want – especially when you gain value from it and other people lose what they hold of value?

34. JOBS CREATED : 155 JOB SEEKERS CREATED  286 (or more )   Why should this not concern us?   First: the Angelides Report  found statistics that allow them to assume that of 585 residents only 286 will be employed. Of the 286 they suggest only  a tiny fraction (9.9%)  will have jobs in Abington . But isn’t it possible that the numbers could be vastly different than that ?  That is a guestimate at best.   Most people seek jobs as near to home as possible, wouldn’t you agree?    If the 365 apartments had just ONE job seeker per apartment  (365), that could make a huge difference in his figures. Many apartments will surely have TWO that work. And if you are suggesting there will be  fewer because so many retired people want to move here, keep in mind what we discussed earlier….  that the retirees will be leaving an Abington home will be replaced by a family that will bring additional job seekers, ie in a multi-generational household.   So for jobs and students, the houses the retirees leave behind have a financial consequence, don’t they? We actually could be many, many jobs in arrears after their supposed " job creation “, couldn’t we? And the new jobs are mostly marketing, leasing, janitorial, maintenance, etc – while those arriving could displace  executives  & professionals, couldn’t they?  Those are the people that you profile being in your apartments.   Not a great trade, off is it? 

35. NO SERIOUS DISCUSSION OF THE FATE OF THE  MALL WAS EVER HELD, WAS IT ?- It was said that the goal of the added residential was to "save the Mall " and  later said that the money from the sale of the land to Bel Canto would be used to refurbish Bloomingdale’s and therefore would keep Bloomingdale’s from leaving, which would be disastrous to the mall.  But no serious discussion of this in detail has been conducted, has it ? And wouldn’t  Bloomingdale’s have to greatly increase their business to cover the investment of millions and make sense?  Will a simple makeover do that? No real math has been presented, has it? And is there anything even keeping Bloomingdale’s from taking the money and moving elsewhere anyway? Anything written that guarantees if they do this they will stay? Because the residents will be dealing with traffic, crime  and increased use of libraries, parks and other facilities, increased Police, Fire and Township services,  and we are being told we need to do this to “save the mall” – but again no math has been presented and no clause in writing that Bloomies must stay after the sale – isn’t that correct?  The disrespect to the residents has been......beyond tolerable. Other malls, like Exton, granted approval for residentail, and they sold the mall anyway. They may just want to increase the value as much as possible before they leave.

36. IF THE  COMPREHENSIVE LAND USE  AS IS CURRENTLY PROPOSED  IS PASSED,  WE MIGHT LOSE MORE COMMERCIAL ANYWAY The entire mall could decide that residential is more lucrative than commercial and apply for the residential mixed use, which might then be their right, and our commercial could be  be severely diminished.  The multi-use residential overlay doesn’t say anything about requiring commercial , does it ?  None of these various details have been explored, have they ?  No numbers have been offered.  It would be important for residents to know this before they gave up so much, wouldn’t it?   And for Commissioners to know this before they voted, wouldn’t it ? So any vote on any of this is premature until all of these things are known, don’t you agree? Wouldanything else be responsible?

37. HAS NO ONE ELSE FOUND THE REQUIREMENT OF 20% COMMERCIAL ODD?  Requiring competition for the Mall  seems odd if the goal is “saving the mall” and driving more commercial to them . Can you explain how that makes sense?

38. NOWHERE IN 11 FULL MEETINGS WAS RETAIL ON BOTTOM AND TOP   DEPICTED ON ANY MODEL OF ANY BUILDING ...AND WHY WOULD THERE BE NO ACCESS FROM THE OUTSIDE  TO THE RETAIL? Many of us will have to drive, as we always do, to the shops here.  Forcing us to go inside and not park near our destination has always been a complaint. Having the shops each with an outdoor access AND indoor accessibility is a far better layout for regular patronage. I have  often bought something at Macy's because I could get to it quickly and it was a much longer walk to a boutique store that had the same type of goods but was not near an entrance. Don’t others have the same experience?

39. “BUI LD TO” LINES MAX AND MINIMUMS  ARE ONLY CONDUCIVE TO DEVELOPERS PROFITEERING  FROM EVERY INCH  OF THE PROPERTY- Most suburbanites do not want the kind of urban development being forced upon us .  "Build to " lines remove the sky from our view as we drive through Abington, and an urban feel is created .  Commissioners are very aware that "urban" is not what their constituents want . Allowing the developer to  build as close as 20 ft from the curb …  with a max of 75 ft away only benefits the developer and doesn’t benefit the residents of the Township, does it? Even if an owner wants to grace Abington with more greenspace and sky, he wouldn’t be allowed, would he?  The build to lines should all be removed. PREIT is asking to break many of our codes to favor themselves, but here's a  code that warrants breaking that benefits the residents. Fixing nonconforming GreenSpace amounts is important. Let's move the buildings AWAY from the curb. Just like in Jenkintown- no one wants to stroll along a busy street, do they?

40. PREIT OWNS 15 OR MORE MALLS AND HAS JUST SOLD EXTON SQUARE ….hurray they can use their own money to bail themselves out - not take our rights away.  If they sell enough properties, they can loan Bloomies what it needs to keep them as an anchor, if they truly  believe a boost to them will save their mall - instead of  ruining our zoning code, our commercial space, our intersections, etc.. PREIT caused  the problem by misjudging the market ( and moving to MORE brick and mortar space in as the trend was going against that, didn’t they?)   But they  have sufficient funds to fix it without asking Abington residents to give up what they hold dear, or to ask us to allow a violation of our  zoning codes,  isn’t that true?  Shouldn’t PREIT be responsible for its own problems and not look to Abington residents to shoulder their burden? There are many signs that WE will be supporting them for decades to come if we allow this, don't you think?

41. CONFLICTS :  OUR MONGOMERY COUNTY PLANNER  BOTH CO- WROTE AND WILL REVIEW THE ORDINANCE Our County Planner Michael Narcowicz is supposed to be  reimbursed by PREIT for the time he spent co-writing the ordinance, but it was clear by what he wrote in that ordinance that he was favoring the builder not the residents . So if the builder pays him (via escrow) and Abington pays him and the County pays him ... to whom are his allegiances. There are 3 very different  interests ? So in whose interest is he working?   The residents,  for instance, would like to see non-combustible materials ,  lots of greenspace with the “retention pond” nonsense.  So this conflict of interest seems to loom large, doesn’t it?   Our zoning code says  where there is a conflict in codes, our Zoning Code prevails. But that's not what he did. Seems like PREIT got their money's worth, didn't they?  But we didn't. This conflict of interest is significant, don't you think ?   Mr Narcowicz. in whose interest are you working?

42. IS OUR PAID COUNTY PLANNER THE VERY PERSON WHO REVIEWS THIS PLAN ON BEHALF OF THE COUNTY? Steve Kline Montco Planning Chair (who could have been charged for his Land Use  activities in Abington)  recently  insisted that the County Planning Board did NONE of the  reviews - only the appointed County Planner in each Township did. That would be Mr Narcowicz who co-wrote the ordinance to the obvious favor of the developer. Yet another conflict, isn't it?


43. HOW MANY MEETINGS IS AN APPLICANT ALLOWED TO DRAG RESIDENTS TO ? Refusing again and again to answer questions , and with Commissioners barely asking any questions on behalf of their constituents, and not requiring answers for them... isn't that a classic example of  "death by meeting".  So how many more meetings should  you  be allowed to go to if you still have not answered the questions from the last one? Or even the FIRST one? 


44, THE WILLOW GROVE PARK MALL BUSINESS DISTRICT  IS THE HOTTEST SPOT IN ABINGTON, TEMPERATURE WISE. DOES IT MAKE SENSE TO INCREASE THE CARBON OUTPUT THERE ?  Where is the EAC and the whole environmental crew ..... gone awol?  Other than  a few more trees at Crestmont Park, they seem to have abandonned the idea that greenspace is valuable --- actually vital - haven't they? Does this seem like how you would deal with an areas already so hot? Does increasing the carbon output here seem wise?


45. IF I'M HAVING TROUBLE WITH MY MORTGAGE PAYMENTS, CAN I SELL MY DRIVEWAY  - and have the zoning changed to multifamily residential?  I promise to pay a few extra taxes if I am allowed to double my income and not worry about how it impacts my neighbors!.

 Thank you

Lora