[brief] THE RECORD SUPPORTS THE CONCLUSION THAT THE DRIVEWAY MUST BE LOCATED ON THE FLORENCE PORTION OF THE PROPERTY.  As the Resolution and the transcript make abundantly clear, the primary issue of concern was traffic.  Since the principal use and accessory uses were permitted on both sides of the municipal boundary line, the Defendant honed in on height, the only measurable difference between Florence’s SM and Mansfield’s ODL Zones, in order to concoct a story in which traffic might be an appropriate consideration.  Again, Defendant’s focus on the height difference between Florence’s SM Zone, and Florence’s GM and Mansfield’s ODL Zones, is a red herring at its core.  After all, the proposed accessory uses in Florence - - parking, stormwater management facilities, septic, and the driveway location - - are permitted and height neutral.  Ja085; Ja097; Ja146.  The Resolution draws special attention to the driveway’s location on the Florence side of the tract, and determines that the “practical effect” of the approval would be imposition of a “substantially more intense use upon lands in Florence[.]”  Ja044.  Even if the Court accepts Defendant’s unfounded assumption that the increased height leads to higher intensity which leads to increased traffic, this assumption can only rationally be extended to the driveway.  The other accessory uses, parking, stormwater management facilities, and septic, are calculated by square footage.  Ja097; Ja146; Ja158-Ja159; 4T 9:6-25.  The record includes clear and concise reasons for the driveway’s location in Florence.  As already discussed above, Plaintiff’s professionals provided the following reasons for the driveway location: (1) it lines up with the driveway design for the proposed project on the other side of Florence-Columbus Road; (2) it is at “the furthest end of the property to maximize the distance from the Route 295 interchange to provide for safe vehicle movements and to prevent any backup off of the [Interstate 295] off ramp”; (3) the limited frontage in Mansfield, that is “not really suitable for access, given the lack of … a spatial separation along that frontage from the I-295 egress ramp”; and (4) collaboration and agreement with the County of Burlington as Florence-Columbus Road is County Route 656.  (1T 34:4-23; 2T 77:12-18).  Furthermore, Defendant’s conclusion also directly contradicts the unrebutted traffic testimony provided by Plaintiff’s traffic engineer, [...].  [...] testified that eighty percent (80%) of the site’s traffic will exit east, a distance of 1,600 feet, to access Interstate 295.  (2T 35:2-13, 36:9-19, 37:17-21).  The other twenty percent (20%) would travel west along Florence-Columbus Road (County Route 656) to Route 130 to access the New Jersey Turnpike – Pennsylvania Extension.  (2T 35:2-13, 36:9-19, 37:17-21).  Importantly, Interstate 295, Route 130, the New Jersey Turnpike, and Florence-Columbus Road, are all within the jurisdiction of the State or County; none are municipally controlled roads.  (2T 35:2-13, 36:9-19, 37:17-21).  In addition, [...] concluded that the impacts on Florence-Columbus Road and Route 130 Intersection, located 1.53 miles from this proposed driveway, would be *de minimis*.  (2T 35:2-13, 36:9-19, 37:17-21; 4T 10:13-19).  While much is made by Defendant about traffic and the potential impacts from the location of the driveway, the record makes clear that the location is required for safety and functionality.  Regardless of the driveway’s location, eighty percent (80%) of the site’s traffic will be traveling *away* from Florence, on State and County roads.  Since the Resolution’s findings and conclusions are not supported by the record, the decision is arbitrary, capricious, and unreasonable.