Statment by Jeffrey Levine


Comments made by Jeffrey Levine
before the Planning Commission of the Township of Lower Merion, Pennsylvania
January 11, 2005


My name is Jeffrey Levine. I am a member of the Township's Historical and Architectural Review Board, a member of the Ard-Wood Civic Association's Board of Directors, and a constituent of Ward 8 in Ardmore.

Hillier's Plan, your plan after this evening, does not include Lancaster Avenue as a specific project area, as recommended by ULI. We make the following 11 recommendations to help improve the business environment along this important artery and elsewhere in the district:

1. Stronger action by the Township and business community to promote the private rehabilitation and development of commercial and residential space.

2. An active program to advertise the availability of CDBG funds, assist owners in obtaining rehabilitation loan funds, and promote the use of rehabilitation tax credits. Regarding the latter, on January 5, Representative Dan Frankel reintroduced House Bill 26, Pennsylvania State Historic Preservation Tax Credits for commercial properties.

3. Educate the business associations with regard to brand management, develop a promotional vision that builds on our past, and market the Ardmore brand.

4. Strictly enforce the Township's building and fire codes to upgrade existing retail and residential properties.

5. Re-examine the Ardmore Special Services District zoning code to permit more flexible use of building spaces, encourage second floor rentals, and allow for the removal of abandoned signs.

6. Offer local tax incentives to building owners who substantially rehabilitate their properties within the next 5 years.

7. Simplify the zoning code that applies to the business district to make change easier. There are simply too many overlays and business owners are deciding to do nothing rather than wade through the maze of regulation.

8. Amend the Zoning code to make combining buildings easier.

9. Amend the zoning code to permit 2d floor retail space.

10. Simplify, shorten, and better advertise the HARB review process.

11. Take a page out of Suburban Square's and King of Prussia Mall's scripts and eliminate parking meters for all but the most desirable parking spaces.

Pennsylvania's Urban Redevelopment Law (35 PS Section 1701 thru 1719.1) makes it very clear that you, the Planning Commission, any only you, have the authority to prepare a redevelopment area plan. In fact, Section 1703 defines a redevelopment area plan as "a plan for the redevelopment of all or part of a redevelopment area made by a planning commission." As such, we urge you to consider our plan as an alternative to Plan B as it is one that builds on consensus, gives appropriate consideration to the preservation of existing historic buildings, fully complies with Chapter 88 of the Township Code, and satisfies the critical program requirements for the redevelopment area.

I would also like to make the following points:

1. Plan B, as presented, does not comply with your own resolution of July 29, 2004, approving the establishment of a redevelopment area: "In evaluating any proposed plan for redevelopment within the redevelopment area, the Lower Merion Planning Commission desires that appropriate consideration be given to preservation of existing historic buildings and districts." Regarding the train station area, Plan B is the Gateway Plan, with no further consideration given to historic resources.

2. Plan B, as presented, violates public policy as stated in Chapter 88 of the Township's Code: "that the preservation and protection of buildings . . . of historic . . . merit are public necessities and are in the interests of the health, prosperity and welfare of the people of Lower Merion Township."

As a matter of public policy, the Code requires that the Township:

  • "Promote the general welfare by protecting the integrity of the historic resources of Lower Merion Township."
  • "Discourage the unnecessary demolition of historic resources."
  • "Provide incentives for the continued use of historic resources and facilitate their appropriate reuse."
  • "Encourage the conservation of historic settings and landscapes."
  • "Promote retention of historical integrity in the context of proposed land use and/or structural changes."

3. Plan B, as presented, flies in the face of consensus. Over the past months I have seen consensus reached among and within the various stakeholder groups. I don't for one minute believe that consensus cannot be reached on a redevelopment plan. I challenge you, and the Commissioners, to make an attempt at consensus. To refuse to even make the attempt, as has been the case thus far, wreaks of impropriety.

4. Lastly, Plan B, as presented, is fiction. I would like to suggest that no matter what plan you approve, it be made perfectly clear that no project proposed under the plan be permitted to take advantage of the impervious coverage, height, or footprint incentives contained in the pending MUST overlay zoning ordinance. To do otherwise is to deceive an unknowing public, for you know as well as I that every project on that map will grow to its maximum.

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