Comments on the Princeton Code Diagnostic (September 2026)

Adam Wolf · 82 Spruce Street · Submitted as a resident-owner in a residential district

Summary of requests

  1. Identify the contract task and the portion of the $305,780 not-to-exceed fee covering the Land Development Code articles (18–23, 27, 28), and state whether the scope was expanded at Task 1-1 and when Council authorized it.
  2. Publish the complete inventory of interests, organizations, and neighborhoods consulted in preparing the Diagnostic — who was interviewed under Task 1-4, in what capacity, how neighborhood representatives were identified, and which residential neighborhoods were represented.
  3. Add Notice as a required element of the uniform article structure (p. 59), so every approval type states on its face who decides, whether a hearing occurs, and who receives notice.
  4. Publish, with the first draft, a table of every approval type showing current versus proposed decision-maker, hearing requirement, and notice radius.
  5. Where a threshold or by-right permission replaces a hearing, identify the objective standard that now performs the review the hearing performed.
  6. Publish a capacity analysis: additional dwelling units and bedrooms permitted by right, by district, under the proposed framework compared with the current code.
  7. State, per district, which intensity controls are retained before any dimensional control is eliminated.
  8. Publish the criteria that determine which neighborhoods become Traditional Neighborhood or Neighborhood Mixed Residential, before the first draft.

Page-by-page comments

p. 3 — “meetings and listening sessions with code users”

Task 1-4 of the Camiros proposal (p. 18) lists who would be interviewed: staff, elected bodies and commissions, business interests, realtors, developers, neighborhood representatives, “and others identified by staff.” I asked Director Lesko in writing on May 19 to participate and was told public events would occur over the next year and a half. Who from the Tree Streets neighborhood was interviewed, how were neighborhood representatives identified, and how many were residents rather than institutional or industry stakeholders?

p. 3 — the Land Development Code

The RFP made the Land Use Code overhaul optional (§II.G). The Camiros proposal names it only in the cover-page title: the cover letter is captioned “Re: Unified Zoning Code Update” (p. 1), the Scope contains no task for subdivision, site plan review, approvals, or administration (pp. 18–20), and the $305,780 fee is itemized by those same tasks with no Land Use Code line (p. 25). Director Lesko’s August 21, 2025 memo describes updating “the related sections of the land use code.” A 28-article reorganization is not related sections. Which task and which dollars cover this work?

p. 6 — proposed article structure

Fourteen articles are zoning (4–15, 17, 25). Eight are the remainder of the Land Use Code (18–23, 27, 28) — the procedural spine of development review, and precisely the optional §II.G work. None of the four articles marked as needing no substantive revision (15, 16, 17, 24) falls in that group.

p. 11–12 — ADU permissions

Allowing ADUs wherever single-family homes are permitted, on lots of 3,000 square feet, with the three-room limit and entrance-orientation rule removed, is a meaningful benefit to homeowners. It is also a second unit available by right on most residential lots. How many additional units does this permit town-wide, and what has the existing ADU ordinance produced to date in unit counts, sizes, and rents?

p. 14 — measure height in feet only

Removing the story limit while keeping a height in feet invites four stories where three were intended. If stories are dropped, what floor-to-floor assumption sets the height limit in each residential district?

p. 14 — eliminate height-to-setback ratio

This control is what keeps a taller building from looming directly over a neighboring lot. The Diagnostic offers stepbacks, transition standards, and contextual setbacks as substitutes. Those should be drafted and shown before the ratio is removed, not after.

p. 14 — eliminate floor area ratio

FAR limits total built area. With FAR, lot depth, and combined side setbacks all removed, lot coverage and impervious coverage become the only remaining limits on how much of a lot is built. Which districts retain both, and at what percentages?

p. 15 — “controls related to maximum heights, minimum setbacks, and lot coverage are more effective”

That may be true, but the numbers are the whole question. This recommendation cannot be evaluated until the proposed heights, setbacks, and coverage limits are published for each district.

p. 15 — eliminate lot depth

Rear yards are where the trees, gardens, and permeable ground are. Eliminating minimum lot depth tends to convert that space to building. What replaces it as a control on rear-yard depth?

p. 15 — eliminate combined side setbacks

Combined side setbacks prevent two buildings from crowding a shared line even where each meets its individual minimum. If they are removed, what minimum individual side setback applies in each residential district?

p. 16 — eliminate lot area per habitable room for multi-family

The stated rationale — that this standard penalizes layouts with additional rooms — describes its purpose rather than a defect. It is a bedroom-density control. Lot area per dwelling limits unit count but not unit size or bedroom count, so the two are not substitutes. In a community where rental housing is priced per bedroom, this is the provision that most directly limits bedrooms per lot. If a per-room standard is hard to administer, propose a replacement metric — maximum floor area per unit, bedrooms per unit, or bedrooms per acre — rather than leaving intensity to the building envelope.

p. 17 — eliminate usable open space per habitable room

Replacing a formula with a percentage-of-site standard is reasonable in principle, but the details matter. Two questions: does the percentage apply to smaller multi-family developments or only to larger ones, and is required open space measured net of stormwater features? A rain garden is not a place to sit outside. If on-site open space is reduced for multi-family housing, while single-family lots keep their yards, the implication is that the only open space for multi-family housing is public parks.

pp. 19–31 — residential lot size analysis

The conformity percentages drive the proposed district consolidation, so their basis should be stated: are they computed by parcel count or by land area? If they are by land area, the figures are clearly biased by the inclusion of non-residential parcels including school, church, cemetery, and other institutional parcels lying within residential districts.

p. 32 — “Specific district boundaries… will be evaluated during preparation of the draft Code”

The Municipality’s own 2023 Master Plan FAQ told residents that the Land Use Plan map’s ten categories are not zoning districts, are shown per acre rather than per lot, and that zoning would not be changed by the plan. That means this process — not the Master Plan — is where district boundaries are actually set. Residents should be told that plainly, and the criteria for assigning neighborhoods to district types should be published before the first draft.

p. 33 — create a higher-density residential district

This proposes a district allowing taller multi-family development “without special approvals,” to be adopted in the text even if mapped nowhere initially. Adopting the district definition is the difficult step; applying it to parcels afterward is a map amendment. Two requests: state the criteria and candidate locations before adoption, and confirm that any later mapping of this district will require the same public process, with extensive public engagement, and individual mailed notice to affected owners.

p. 33 — neighborhood types

Traditional Neighborhood contemplates duplexes through townhouses, and Neighborhood Mixed Residential contemplates multi-unit as a transition from mixed-use areas to lower-density neighborhoods. Publish the criteria that determine which existing blocks become which type, and the draft map, together rather than sequentially.

p. 35 — R-1/AH and R-2/AH districts

Consolidating site-specific affordable housing districts into a general framework is sound. The same principle should apply going forward: site-specific affordable housing districts should be broadly consistent with the standards of the surrounding neighborhood rather than written for a single parcel.

p. 35 — cottage courts

The text proposes cottage courts as a permitted use in RN-1 through RN-8, while p. 33 states that the intent is not to introduce these types into every residential district. Which is it, and how many RN districts are contemplated?

p. 35 — splitting large single-family dwellings into multiple units

The Diagnostic acknowledges that conversions increase density in neighborhoods designed as single-family, and that parking is the key issue. Please publish the proposed gross floor area, lot size, and unit size thresholds, and the parking standard, before this advances.

p. 46 — exterior lighting

If the code enables ADUs, conversions, cottage courts, and denser residential forms, fugitive light onto adjacent properties becomes a real issue. Retain and strengthen measurable limits on light trespass at residential property lines rather than relaxing operational requirements.

pp. 49–50 — parking ratios and elimination of minimums

For residential development, parking is governed by the Residential Site Improvement Standards (N.J.A.C. 5:21), which municipal zoning cannot simply set aside. Please explain how the recommendation to consider eliminating parking minimums squares with RSIS in residential districts. Separately, Princeton has block-level parking studies, so the claim that minimums are “arbitrary” can be tested locally rather than asserted generally. In the Tree Streets, on-street capacity is already at its practical limit. Which districts are contemplated for exemption?

p. 50 — parking fee-in-lieu

Parking impacts are intensely local; a municipal fund is not. If a fee-in-lieu program is adopted, what assures that funds collected from a development are spent on parking serving that development’s immediate area?

p. 51 — bicycle parking

Support. Treating bicycle parking as core site design rather than an afterthought is the right approach.

pp. 59–60 — zoning administration

Add Notice to the required structure for each approval type (Purpose, Applicability, Authority, Procedure, Approval Standards, Expiration). A resident reading the code should be able to see, from the article itself, whether a decision is made at a counter or at a noticed hearing, and who is told.

p. 60 — eliminating §B17A-209 and §B17A-210 relief pathways

Support. Routing all relief through the MLUL variance framework increases transparency and brings statutory notice to proceedings that currently avoid it.

p. 61 — administrative encroachment permit

This moves a class of decisions off a public Council agenda to an administrative sign-off. Please define the boundary precisely: what objective criteria separate a minor encroachment from one that continues to require Governing Body review, and is any notice given to abutting owners?

p. 61 — site plan review thresholds

Streamlining review for minor projects is reasonable, but a project below a threshold gets no noticed hearing and no neighbor notice. Publish the current and proposed thresholds side by side, with an estimate of how many recent applications would fall below the new ones.

p. 61 — UHAC modification procedure

UHAC constrains a developer’s ability to make affordable units a lesser tier of housing. Any modification procedure should be limited to unit mix, require public process, and state expressly that it cannot be used to reduce the bedroom distribution, size, or quality standards that UHAC exists to protect.

p. 62 — sustainability bonuses

Earning additional height and lot coverage through a points system converts an environmental program into a density bonus. If adopted, cap the bonus, exclude it from residential districts, and state the maximum height and coverage attainable with all bonuses applied.

pp. 64–65 — nonconformities

Support the reconstruction provision, the deemed-conforming provision, and the permitted expansion of nonconforming walls for single- and two-family homes. These let owners of older homes invest without a variance. The limitation on p. 65 — that development on a nonconforming lot is restricted to the dwelling type matching the lot size — should be retained in drafting.