All right. And your office is in, we call it northern New Jersey?
Correct.
And did you come into the property or see the property before issuing your report?
I have not.
And I saw your voluminous, extensive resume, which certainly shows competence in many areas.
But if I counted correctly, your resume shows 40 municipalities where you've worked, all in New Jersey, 30 traffic studies.
all in New Jersey, 30 traffic studies, no mention of Philadelphia, and four expert testimony cases,
no mention of Philadelphia. So is it a fair statement to say this is your first
opportunity in testifying before the zoning board on a matter of Philadelphia zoning?
That's correct. All right. So I would stipulate that he's a traffic engineer and he has experience,
but I would object to calling him an expert in Philadelphia land use.
We have our own zoning code.
We don't follow the municipality's planning code, and he's a novice,
but I think that goes to the weight of his testimony in Philadelphia.
Just a quick rebuttal to that.
His testimony is not about the zoning code per se,
but about the report that was submitted by the applicant
and those standards for traffic.
So in that regard, he should...
So we're going to recognize him as a licensed engineer, and, you know, he has done a lot of work outside of Philadelphia, but I'm not going to call an expert witness, okay?
But you can start your testimony.
Thank you.
Mr. Klein, were you present in the room when this hearing first was heard back in March?
No, I was on Zoom.
But you listened to the testimony, correct?
I listened to the testimony.
I believe it was March 4th.
And you've been provided and reviewed all the documents that were presented, including the applicant's traffic study?
That's correct.
Okay. And if you could, just give us your assessment of the applicant's report and your observations overall as a traffic engineer.
Sure. There are about five or six points that I want to make about this application.
The first point is in the traffic impact assessment that was performed by TPD, the applicant assumed, based on information provided by the client, that 70% of the students would arrive by non-vehicular method.
They would either walk or take mass transit.
I stipulate that the impact study has failed to explain or provide backup data for that.
The school exists on Lombard Street.
They could have done a count there to count the number of cars, number of students, the walking students, the number of cars that were dropped off, how many students in each car, to come up with that number.
So they've assumed that number, and I don't believe that there's enough data to support that.
So now they've got a frontage along their site that's about 112 feet wide along South 8th Street on the site that they're proposing.
They're proposing a 12-foot wide driveway.
So there's about 100 feet left, and that maximum of about four cars could queue up along their frontage to drop off and pick up students.
And what my issue is with this is that there are only four parking spaces available for that.
if there are more than four cars dropping off within the same minute or two, then traffic is
going to queue up and back up out onto South 8th Street and could potentially block at least one
travel lane on South 8th Street. I also noted that when I looked at street view around the area,
there are times when the apartment building across the street, the Bradford Apartments,
They have deliveries and mail trucks show up, and there's times when that left lane of southbound 8th Street would be blocked.
So there could be times when south 8th Street could be blocked completely by either a vehicle stopped at the Bradford or vehicles queuing up beyond the four cars that the capacity for the drop-off has.
uh the traffic impact study stated that there was no traffic impact for the development the traffic
impact study also mentioned that they studied the peak hour of the drop-off and my contention
is based on my experience and my observations at other schools private schools public schools
that when there's a start time at the school the drop-off period is typically 15 to maybe 20 minutes
long people concentrate in that 15 to 20 minute period to drop off their children they don't need
to drop them off extra early they want to be able to get there drop their kid off and go on their
way to wherever they have to go next uh also i would say that the the pm pickup time would
actually be worse in some of my observations of private schools and public schools were drop off
and pick up a car by personal vehicles, those vehicles tend to arrive on the early side.
So if school ends at, let's say, 2.30, the vehicles start to arrive at 2 so they get a good parking spot
because they need to take their child to their next activity in the afternoon.
So that will definitely be queuing up more than four vehicles for probably a good half hour to 40 minutes.
And the traffic impact study did not address that.
And the traffic impact study did not address that.
There's also the 230-seat auditorium in the property, in the first floor, I believe, that is going to have some sort of events there.
There's no mention of where people will park for those events.
And again, if it's going to be 70% of the people are not going to drive, but 30% are going to drive,
There's still a significant amount of traffic that could be generated by the 30% of the people that arrive to come to those sites.
I didn't see anything about garbage and recycling collection.
Again, because of the narrowness of South 8th Street, and there is no ability for a garbage truck or even a delivery truck to pull into the site to be able to pick up garbage, recycling, and drop off, let's say, lunch.
uh produce and things like that for meals uh i also looked at the parking layout on the site plan
sheet z11 uh it has an amendment uh from the zoning board amendment number two revision date
uh march 26 2026 that drawing shows the the 12 foot wide driveway it also shows that the parking
spaces in the site are only eight feet six inches wide which is typically less than a nine foot wide
standard parking space they do provide 18 foot long parking spaces but the drive aisle to be
able to maneuver into those narrow parking spaces is only 18 feet six inches so i would say that if
if they are able to maneuver it's going to take a lot of maneuvers to get in and out of those spots
the parking spaces i believe it's seven and eight that are closest to the wall they don't have
enough room to maneuver out to be able to make enough k turns to be able to get out of the site
or even to get into those parking spots so i would say that they do not have 12 parking spots in that
property they need to get it down to probably 10 or even less but that's it the drive aisle is so
narrow they may have to lose a whole row of parking so they may get it down to maybe six
parking spaces if they were to design it properly
so just to sum up so 30 will drive but there's no data to support that they could have easily
counted cars over at the lombard facility and the lombard facility has parking off-site you're not
allowed to stop on lombard street there's signs posted there so cars do pull into the site drop
off children circulate around and come back out it could have easily counted the number of cars
that are on site to drop off and pick up but they did not uh i believe that the four spaces in front
will be adequate we also need to be able to reserve those spots for particular times for
drop off and pickup i also think that the level of service is understated because they didn't
concentrate the drop off and pick up and the arrival traffic and the departure traffic
traffic in that 15 to 20-minute period. Quadruple, multiply by four, or multiply the traffic
generated by the site by at least three to show what it would be for analyzing one full
hour. Also, again, the event space was not accounted for. How many events will there
be? If there's 230 people here, how many of them are going to drive? Where are they going
to park? They didn't do a study of the area to see that, oh, yeah, there's a parking garage
that has availability in the evenings, and we've secured 40 parking spaces in that garage.
They could have come up with a mitigation for that, but they did not.
So that's my direct testimony.
Mr. Klein, as part of your review and preparation for today,
did you review the Philadelphia Zoning Code in particular, the requirements for a variance?
no i just i reviewed just the traffic impact study and uh the presentation material that
was presented back in march and the site plans and so forth okay but are you familiar with uh
the requirements for a variance as it relates to traffic and impact uh for a use variance i i'm
sorry i would actually have to look that up yeah okay i have no further just from the vera just a
few. Mr. Klein, how many travel lanes are there on South 8th Street? Two travel lanes southbound
and then the one parking lane on the right. Okay. And you didn't do a traffic study. You did a
critique of TPD's traffic study. That's correct. In my experience, it's the applicant's burden to
be able to show that something works. I'm just pointing out the faults in that report. All right.
So it's a criticism rather than an independent study that would otherwise satisfy the street department or PennDOT or New JerseyDOT.
PennDOT or New JerseyDOT? I'm not sure I understand the question. So what you submitted,
I'm not sure I understand the question.
you could submit to, you know, any authority as a study. It's a critique based upon
a review of somebody else's study. That's correct, yes. And with regard to
the synagogue, which is nearby, which has been operating for many, many, many years,
and the preschool there uh do you recall the rabbi's testimony regarding uh how they have
been able to manage uh that process successfully and without incident uh and that's why they're
so confident that the numbers will work out in favor of walk-ins for a street
yes but like yes but like I said in my testimony that site has off-street parking more than four
cars can be accommodated and more than 12 cars I believe would be accommodated if if they were to
use that parking in the garage the 12 spaces for drop-off pickup I don't in my opinion that would
not work the dimensions are not correct but if they're using the four parking spaces along South
8th street that's way undersized compared to what they have on lombard plus lombard i believe they
only have about 70 students here they're going to have 180 students so it's going to be even worse
on in this location did you talk to the city's department of streets regarding their review of
the plans the parking layouts access and the like i did not um and i would just say finally
with the regard to this neighborhood you didn't go there on purpose but you are
familiar with, obviously, this is a very dense urban neighborhood with multiple schools in the
immediate vicinity of all types of persuasions? Yes, I've looked at Google Street View,
aerial photographs, and so forth. Yes. It's not like a strip market or a strip mall or
some other facility in Piscataway or upstate New York, is it?
No, and I've done work in Jersey City and Hoboken, Newark. I've done work in urban areas, and I've done daycare centers and schools within urban areas, and we've got to provide enough drop-off capacity and pick up capacity so it doesn't impact the public street.
Right, and you said you were familiar generally with the zoning code, but are you familiar with the non-residential uses that are permitted by special exception in this district?
No, I just did a critique of the traffic impact assessment and the site plan.
Would you be surprised to know that they include schools, religious institutions, hospitals, and the like in the RM1 district?
Objection, relevance. This is not a special exception case.
Well, the comment is that if we were able to satisfy the special exception criteria, then these uses would be by special exception, which is a common condition as a permitted use and not at all exceptional.
So that assumes this is a detached building, which it's not.
Sure. So I note your objection, but I'm going to allow the testimony.
So, are you familiar with the special exceptions allowed in RM1 district where this property is located?
What my role was was to review the site plan, to review the traffic impact assessment, to review the potential drop-off and pickup issues, and I came up with these criticisms based on what I observed, what I analyzed in their reports and site plans.
So, the answer is no?
Yeah, correct. That's correct.
yeah thank you you want to follow up i do not or do you want to try your other call
i would love to jerome jerome am i right that's correct jerome and if you can pronounce his last
name no i might that's why i said jerome jerome has been promoted to penalize thank you and and
council just so you know you have 10 minutes i know okay did you want to swear him in or yeah
excuse that jerome i gotta get his get him on the mic first
jerome yes hi jerome could you please state your name and spell it for the sonographer
Yes, it's Jerome, J-E-R-O-M-E, last name Skrinkoski, S-K-R-I-N-C-O-S-K-Y.
Do you swear or affirm to tell the truth, the whole truth, nothing but the truth?
Counsel?
Thank you.
Mr. Skrinkoski, forgive me if I mispronounce that.
What is your profession, please?
I'm a professional planner, planning consultant, zoning consultant, and community development consultant.
I'm a professional planner, planning consultant, zoning manager.
And are you a member of the American Institute of Certified Planners?
Yes, I've been a member of the American Institute of Certified Planners for 25 years.
I also have a total of 41 years of professional experience.
And is your CV attached to your report?
yes and approximately how many times have you testified before zoning boards
in pennsylvania um close to a thousand i would say have you ever testified before this board
no do you think that precludes you from being an expert in this matter no i'd like to offer
mr skrinkowski as an expert in zoning and land use planning and i would agree generally but i
I would say that expertise does not follow through with county of the first class of
Philadelphia, which has its own home rule charter, its own zoning code, and its own
unique issues.
So we'll accept him as an expert witness, but obviously not as an expert in Philadelphia.
Thank you.
Mr. Skrinkowski, have you reviewed the original application, the original plans, the original
notice of refusal revised refusals and were you also present at the last uh meeting uh virtually
yes and were you also provided a copy of the development and operations agreement
that was entered into between the applicant and lombard muse yes okay and did you listen to the
testimony that was previously presented by the applicant yes and did you review the philadelphia
zoning code as part of your presentation for this matter? Yes. And did you prepare a written
land use and zoning report for this matter? Yes. Are you familiar with the definition of an
educational facility under the Philadelphia zoning code? Yes, I am. And what is your
understanding of what that definition is? The public and or private school at the primary,
elementary, junior high, and high school level that provides basic education.
Okay. You're aware that the current notice of refusal no longer has reference to religious
assembly, correct? That's my understanding. But the original notice of refusal did,
is that right? Yes. And are you familiar with the definition of that religious assembly under
the zoning code yes and uh i think i might have referenced it but if i did not it's a religious
services involving public assembly that customarily occur in synagogues temples mosques
churches and other facilities used for religious worship okay the development agreement that was
entered into with the applicant and lumbar abuse that permits weddings correct uh no it uh it
permits um it's my understanding that it would permit weddings yes and bar and bat mitzvahs yes
and an annual week-long celebration of sukkot yes as well as indoor celebrations of all jewish
holidays with the right to serve liquor that's my understanding yes and in your professional
opinion as a land use and zoning expert are those activities typical or customary for a k-8 school
uh no because um what the applicant is asking for was to establish um a educational use
and those would be subordinate uses that would not be necessarily permitted as part of a general
or as an educational use. So even if they were to be considered subordinate, would you think that
would you consider them to be necessary to have a school? No. Okay. Are you familiar with what a
non-conforming use is under the Philadelphia zoning code? Yes. And if I said to you that
it was a use lawfully established that does not comply with current zoning regulations
is that what your understanding is that would be correct does this application
deal with a non-conforming structure the case should would apply to a non-conforming structure