Robert M. Tucker Direct Dial: (610) 941-2484 Direct Fax: (610) 684-2006 Email: [email protected] www.kaplaw.com April 20, 2021 VIA EMAIL [[email protected]] & HAND DELIVERY Kevin W. Kochanski Radnor Township 301 Iven Avenue Wayne, PA 19087 RE: 250 King of Prussia Road - ZHB Application for Proposed Parking Structure Our Ref: 6565.42 Dear Mr. Kochanski: I represent BDN 250 King of Prussia I, LP (“BDN 250”), the owner of the property at 250 King of Prussia Road in Radnor Township (“Property”), which is improved with an office building that is nonconforming to the parking requirements of the Radnor Township Code (“Code”). The Property is located in the PLO Planned Laboratory-Office District (“PLO District”). BDN 250 plans to modernize the Property by increasing the amount of off-street parking on the Property by construction of a parking structure over potions of the existing parking lot on the Property (“Project”). On behalf of 250 BDN, I enclose the following: 1. Ten (10) copies of a Zoning Hearing Board Application seeking: a. Variances from Code §280-64.C to permit (i) a setback of 43.39 feet (+/-) opposite King of Prussia Road to and (ii) a setback of 17.16 feet (+/-) opposite Radnor Chester Road; b. A variance from Code §280-64.B to allow a building/structure area of 42.2 % (+/-); c. A variance from §280-§280-64.B to allow a landscaped area of 29.4%; d. Any other relief deemed necessary for the Project; Kaplin Stewart Offices in Union Meeting Corporate Center Pennsylvania 910 Harvest Drive, P.O. Box 3037 New Jersey Blue Bell, PA 19422-0765 610-260-6000 tel 7004691v1 Kevin W. Kochanski April 20, 2021 Page 2 2. A $900.00 check payable Radnor Township, the required Zoning Hearing Board application fee; and 3. An electronic version of the application. Please place this matter on the May 20, 2021 agenda of the Zoning Hearing Board. Please provide us with prior notice of the scheduling of the public hearing on the application. Also, please provide us with copies of all comments, reviews, and/or communications regarding the Project and/or this application as soon as they are generated and/or received. If you have any questions or require any further information, please contact me. Thank you for your attention to this matter. Sincerely, Robert M. Tucker RMT cc via email: BDN 250 King of Prussia I, LP Landcore Engineering Consultants, P.C. 7004691v1 $WWRUQH\’s QDPHBBBBBBBBBBBBBBBBBBBBBBBBBBBBBBBBBBBBBBBBBBBBBBBBBBBBB*HRUJH : %URVHPDQ 5REHUW 0 7XFNHU $GGUHVVBBBBBBBBBBBBBBBBBBBBBBBBBBBBBBBBBBBBBBBBBBBBBBBBBBBBBBB +DUYHVW 'ULYH 6XLWH %OXH %HOOBBBBBBBBBBBBBBBBBBBBBB 3$ 7HOHSKRQH QXPEHU BBBBBBBBBBBBBBBBBBBBBBBBB (PDLO BBBBBBBBBBBBBBBBBBBBBBBBBBBBBJEURVHPDQ#NDSODZFRP 5HOLHIUHTXHVWHGDQGRUEDVLVIRUDSSHDULQJEHIRUHWKH=RQLQJ+HDULQJ%RDUGLQFOXGLQJspecific citation to any and all sections of the Zoning Code relevant to the appeal. 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Broseman, Esquire Robert M. Tucker, Esquire Identification Nos.: 62649/318586 Attorneys for Applicant Union Meeting Corporate Center 910 Harvest Drive Blue Bell, PA 19422 (610) 941-2459 [email protected] www.kaplaw.com BEFORE THE ZONING HEARING BOARD OF RADNOR TOWNSHIP, DELAWARE COUNTY, PENNSYLVANIA IN THE MATTER OF: : PREMISES: BDN 250 KING OF PRUSSIA I, LP, : 250 KING OF PRUSSIA APPLICANT : RADNOR, PA 19087 : FOLIO NO.: 36-02-01158-00 ADDENDUM TO ZONING HEARING BOARD APPLICATION BDN 250 King of Prussia I, LP, through its attorneys, George W. Broseman, Esquire, and Robert M. Tucker, Esquire, hereby file this Zoning Hearing Board application, and in support thereof states as follows: 1. Name and Address of Applicant/Property Owner. The Applicant/Property Owner is BDN 250 King of Prussia I, LP (“BDN 250”), c/o Mr. Joseph Traynor, Brandywine Realty Trust, FMC Tower at Cira Centre, 2929 Walnut Street, Suite 1700, Philadelphia, PA 19104. BDN 250 recently purchased the property at 250 King of Prussia Road (“Property”), which is the subject of this application. The Property is also known as Delaware County Folio number 36-02-01158-00. A redacted copy of the Deed for the Property is attached hereto as Exhibit A. -1 - 7002539v2 2. Description of Property & Surrounding Area. The Property contains 7.23 (+/-) acres of land and is located on the corner of King of Prussia Road and Radnor-Chester Road. Photos of the Property are attached hereto as Exhibit B. The Property is in the Township’s PLO - Planned Laboratory-Office District (“PLO District”), in close proximity to U.S. Route 30 (Lancaster Avenue) and an interchange with the Blue Route, Interstate 476. Photos of adjoining properties and properties located across King of Prussia Road and Radnor-Chester Road from the Property are attached hereto as Exhibit C. 3. Improvements, Use, and Zoning. The Property contains a multi-story office building (“Building”) that was last used as the Penn Medicine at Radnor facility. The Property also has various parking areas, but those spaces do not fulfill the Code parking requirements for the Building. Penn Medicine at Radnor recently moved to a new facility constructed at 145 King of Prussia Road. The existing conditions on the Property are shown on the plan sheet entitled “Existing Conditions & Demolition Plan” dated 2/18/2021, revised 4/15/2021 and prepared by Landcore Engineering Consultants, P.C. (“EC Plan”). The EC Plan is attached hereto as Exhibit D. The Building was built in the 1950’s as an office building for T.V. Guide. The Building subsequently became the headquarters for the Fidelity Mutual Insurance company and thereafter was devoted to use as the Penn Medicine at Radnor medical offices operated by the University of Pennsylvania Health System (“UPHS”). In the 1980’s Fidelity Mutual became the owner of the adjoining property at 259 Radnor Chester Road (“259 RCR”). Fidelity Mutual redeveloped 259 RCR and provided for shared access and some shared parking between the sites. When the building -2 - 7002539v2 was constructed the Property was zoned C-3 Commercial District but was later rezoned to the PLO District. According to the EC Plan the Property is nonconforming to several Code requirements, including the minimum lot size for the PLO District; setbacks from King of Prussia Road and Radnor-Chester Road; the required setbacks for the other lot lines (opposite King of Prussia Road and Radnor-Chester Road); building height; building dimensions; building area; minimum landscaping areas; and the number of parking spaces. Variances have been granted to prior owners relating to, among other things, parking space size and setbacks. Under the current provisions of the Code the Building would require 936 parking spaces and only 373 spaces are provided.1 As will be described below the proposed plan will significantly decrease the existing parking nonconformity, which is needed to modernize the Building. 4. Prior Zoning Hearing Board Decisions pertaining to the Property. Based on a review of public records pursuant to a Right To Know Request the following prior Zoning Hearing Board decisions appear to pertain to the Property. • Appeal 612 (1958) – variances granted to reduce the required setbacks from King of Prussia Road and Radnor Chester Road. • Appeal 1169 (1972) – variance granted to allow parking within the 50 feet parking setback area. • Appeal 1606 (1982) – variances granted to allow the Building to be served by “compact” parking spaces. 1 According to the Proposed Plan (identified below) there 92 spaces in the existing garage space within the Building and 281 surface parking spaces. -3 - 7002539v2 • Appeal 1690 (1983) – variances granted from slope controls to allow construction of various improvements; Variances granted to allow additional compact spaces and other relief related to the development of the adjoining 259 RCR property. • Appeal Nos.