the file um so uh david plant are you on uh yes okay um you just need to be sworn in first
vice chair chanera would you like to swear in uh mr plant yes please identify yourself
for the record spell your last name david plant p-l-a-n-t-e do you swear and affirm to tell the
truth the whole truth and nothing but the truth yes thank you please proceed and uh rich can we
stipulate to mr plant's qualifications as a licensed uh engineer in the commonwealth
pennsylvania absolutely yes mr plant i'll be very brief with you uh you submitted a letter that is
in the record as Exhibit 9 regarding the parking ramp.
Did Rogerio Plant Land Design
design this parking ramp? Yes.
Are the pitch
and incline of parking ramps a zoning
issue? They are not. Okay. Would it be more accurate to say
that these are building code issues? Yes. Notwithstanding
that. Is the ramp that you designed feasible? Yes, it is. And was the ramp approved by
the streets department? The plan was approved by the streets department, yes.
And do you swear and affirm that the letter that you drafted to me that is in the record dated
October 28, 2020 is complete and accurate and truthful as to the ramp feasibility and the
heights. Yes. Okay. I have no further questions for Mr. Planck. Thank you. May I, Mr. Chairman?
Marco, please. All right. May I ask Mike to stop sharing screen? I'll do my share screen in a
minute. Thank you. Mr. Plant, good afternoon. Can you confirm that your business, your engineering group,
Your business, your engineering group, prepared the survey drawing, which was part of this development.
Can you confirm that?
That is correct.
And there was a testimony in the hearings back in last year regarding a portion of the plan that is known as the address 2006 Waverly Street.
Do you were you present for that testimony? I was not. OK. All right. Let me share my screen and I'm going to.
Mr. Plant, can you see what I have on my screen? Yes. OK.
I'm going to indicate with my course, sir. This is your organization, Ruggiero Plant Land Design, correct? That's correct.
And the dates here, this 3-19, 3-12-19 date, this is a lot consolidation survey, correct?
All right.
So over here, it says source of title.
Do you see that?
All right.
And do you see 2006 Waverly Street mentioned there as one of the lots involved in this process?
All right.
And you see there, if I read for the record, it says 2006 Waverly Street, the source of title says deed from Maria Suppresso to Edward Suppresso and Catherine Suppresso dated May 16th, 1975, etc.
Correct?
So in your preparation of this document, you have identified the owner of 2006 Waverly
Street as Maria and Edward Suppresso and Kathleen Suppresso, correct?
Well, I've noted them as the owner of record, reflecting the recorded documents.
Owner of record.
You agree with that?
And that is true and correct at the time you did and prepared this document.
Is that right?
That is what we gleaned from the documents provided to us.
All right.
All right.
But this document, you stand by this document as accurate when it was prepared, correct?
Correct.
All right.
And were you ever aware that a quiet title action was filed with regard to the ownership of the 2006 Waverly Street parcel?
Are you aware of that?
I am aware of that.
But there's nothing inaccurate about this document as to the ownership of 2006 Waverly Street at this time, correct?
As I stated, the owner of record, as stated on the plan, reflects the recorded documents and records available to us.
All right. Very good. Now, I'm going to take you over to the actual survey drawing, and let's just identify for the record.
Do you see what I'm outlining with my course here?
All right. Is that the 2006 Waverly Street parcel that you've identified as the deed of record being the suppressors?
I need to interrupt for a second. I know this is a little over two years ago.
My memory is not as good as it used to be. Are we rehashing the issue of title here?
Wasn't there something about someone didn't live there or lived in Florida?
I mean, did we not? And is it that important to go over this again? I seem to think that we've
already been through all this. Well, no. Correct me if I'm wrong. Correct me if I'm wrong.
Again, I understand it's stale, but what happened was the architect refused to testify on this
portion of the deeded survey and punted all of these issues to the engineer. So I was unable
to establish the record uh and if you recall you know the one of our main challenges to the issuance
of this permit was that the owner did not provide proof of ownership for this particular piece
because there was a quiet title action and yes we spent we did spend some time on it but i never got
to uh speak about the survey because the architect refused to answer the questions and this is why
this piece of this uh record is so important and why i need to make it so uh we never got here to
this point uh uh mr chairman we got sent to we were told we had to ask the engineer these questions
so that is why this was so important why i asked that this hearing be held i i disagree that we've
never got to the point we had a full hearing on this quiet title i thought we did uh the first
hearing that's all that was addressed we didn't even have time to get into any other issues at
the first hearing. We had an attorney who was one of the appellant's husband's partners
partners come out and representing an individual who lived in California. I mean, Mr. Chair,
come out and representing an individual who lived in California.
we have one building that was on this parcel with a single OPA tax number with OPA records
reflecting it as 2,273 square feet, which is the combined size of 414 to 1620th Street and this
2006 Waverly Street address. The city didn't recognize 2006 Waverly as a legal address. They
only recognized one owner. A quiet title action was filed, has been resolved. A corrective deed
is in the record. We believe that this is just simply a red herring. RLDL 20th Street was the
equitable owner of the property at the time the application was filed. Thank you for refreshing
my memory. Yeah, and Mr. Chairman, this particular issue, I've established this is all I needed. I
I wanted to make sure the record was clear at the time this application was filed.
This property was owned by the suppressors and not by a developer, and that was-
That has not been made clear.
You've allowed me to make the record.
That was the key part of my questioning of Mr. Plant.
I never got to ask these questions.
You've allowed it.
We have a complete record on this issue now, and I'll argue it at the appropriate time.
But we never got to establish these facts.
I never got to ask these questions before.
But I can move on to the issue of the ramp, but you're on.
I think that's the issue with the board we'd like to hear about.
All right.
Very well.
We'll do that right now.
So Mr. Plants, let me put up your drawing here.
Thank you for your testimony thus far.
So you've agreed that you did design the ramp for this parking area, right?
Correct.
All right.
You would agree that the code requires that when you propose accessory parking as part of a development, the parking must be accessible.
Would you agree with that, that the code requires that?
That's correct.
Now, you've testified that your ramp is feasible, correct?
Correct.
All right.
So your letter that Mr. Phillips referred to shows that you mentioned that there's a depth of 9.7 feet.
that right for this ramp to travel that's right all right
let's direct your attention to the site plan in this matter uh do you see this the depth here
where my do you see this the site plan here that i have up yes do you see this let me move it up a
bit here. This, this, do you see this, where my courser is? I do. That says a depth of 12 feet,
correct? Correct. All right. So your measurements are different from what was shown on this site
plan to lni correct um well yes um we have a shallower depth to the parking portion
of the of the cellar um the architect may have a another section in the utility room or
some other section that is lower than the parking section the parking section doesn't need to be
that deep but i've imagined you you're standing by your measurement of 9.9 feet 7 inches as opposed
to this depth of 12 feet shown on the plan correct that's right all right let's go back to your
drawing so you would say your your draw your uh depth is the accurate one not the one that's shown
here would you agree with that to the bottom of the ramp and the parking area that we show that's
we have addressed we haven't addressed other areas of the basement all right but you would
agree there the numbers are inconsistent you would agree with that objection
say that again i said i my question is you would agree that the that mr plant's measurement is
is different from the measurement that's shown on the on the site plan i can't make it maybe
Maybe Tom can answer it better than me.
I'm saying you would agree that your measurement is the correct one, right?
Well, as I stated, my drawing addresses the depth, not necessarily to the lowest point in the basement,
but to the parking area and the bottom of the ramp.
So there could be different elevations in different portions of the cellar.
but don't you base your drawing on this on the site plan and uh what that's submitted to l and i
well i i have my my drawing demonstrates what the elevation
well i i have my my drawing demonstrates what the elevation of the parking area the parking spaces
uh counselor counselor the architect and the engineer could have different ceiling heights
because they take it from different points okay all right well let's go back to the let's go back
to the to the to the ramp drawing you see the ramp drawing mr plant all right so there's a measurement
here of of 24 feet right do you see that traverse that's right and that's not an accident right
that's a requirement in the code is it not to have 24 feet wide for driveway aisles that's correct
all right your ramp though extends into that driveway aisle does it not it does okay so and
if we took take a look at your measurements here i see a 20 foot foot measurement
This is a five-feet measurement here, this portion of the ramp, correct?
And then there's a portion of this five feet is also within the 24 feet.
Agreed?
That is correct.
All right.
So the distance from here, the edge of your ramp to the parking that it faces, is somewhere around, let's say, around 17, 18 feet.
Would you agree around 17 feet?
Is that fair to say?
I believe that you're looking at that incorrectly. So what we show here is the ramp and the slope
on the parking aisle floor. So the ramp ends at the edge of the parking aisle, okay,
And in this case, we demonstrated the slope on a portion of the parking aisle.
Now, and I believe that ranges from a tiny amount at 7% and a portion of it at 5% or 4%.
Hold on a minute.
Are you saying that this ramp does not extend?
This is inaccurate?
The depiction of this ramp is not accurate?
The depiction is accurate.
I believe you're misinterpreting that.
That is demonstrating the slope within that driving portion of the aisle of the ramp.
That's right there, right?
However, the aisle is 24 feet.
Just because we showed a couple of lines indicating the breaks and slope, that doesn't mean that it is ramp or dry vial.
What I'm showing there is a depiction of the slope and the last five feet being 4%, approximately another two feet at 7%.
And those areas are within the drive aisle, but the entire drive aisle would be sloped in that way.
So it's not a separate ramp. It's not a separate structure.
So then, you know, I don't really, Mr. Plain, I'm not following it.
Let me ask you, let me try to ask it more simply.
There's no discrete structure along those lines, okay?
Well, what is the distance from the end of the ramp to this parking space right here, if it's not somewhere around 17 feet?
Well, it's 24 feet.
So the edge of this ramp should be back here, aligned with this parking area?
Why wouldn't you just have shown that?
Well, I'm showing you the slope all the way down to the main portion of the drive aisle.
But you have footage, you have a foot measurement here.
Why would you show it as five feet, five feet, five feet if that's not what it is?
Well, that is what it is.
That's a slope, that's to show the break in grade from those different grade percentages.
Am I seeing this correctly, that five foot that Mr. DeMarco is speaking?
It looks like the line at the top is lighter in shade compared to the other.
And is that something that architects or the way this thing is drawn out?
Those lines, the lines along the side, they have no significance.
And the vertical line at the end of the five feet could stretch all the way across the entire 24-foot drive aisle.
Because you're showing the slope.
Let me ask a simple question.
For all intents and purposes, correct me if I'm wrong, if I understand Mr. DeMarco's question,
that should only be the five foot and five foot.
And we could eliminate that last block of five feet and four percent?